ML102100096

Updated License Renewal Application Commitment List and License Renewal Application Amendment No. 20

ML102100096
Person / Time
Site:	Palo Verde
Issue date:	07/21/2010
From:	Hesser J Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06224-JHH/GAM
Download: ML102100096 (72)

Text

A PS A subsidiary of Pinnacle West Capital Corporation John H. Hesser Mail Station 7605 Palo Verde Nuclear Vice President Tel: 623-393-5553 PO Box 52034 Generating Station Nuclear Engineering Fax: 623-393-6077 Phoenix, Arizona 85072-2034 102-06224-J H H/GAM July 21, 2010 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1,j2, and 3 Docket Nos. STN 50-528, 50-529 and 50-530 Updated License Renewal Application Commitment List, and License Renewal Application Amendment No. 20 By letter no. 102-05937, dated December 11, 2008, as supplemented by letter no.102-05989, dated April 14, 2009, Arizona Public Service Company (APS) submitted a license renewal application (LRA) for PVNGS Units 1, 2, and 3.An updated LRA Table A4-1, License Renewal Commitments, is provided in Enclosure 1, LRA Amendment No. 20 Clean Pages, and Enclosure 2, LRA Amendment No. 20 Markup Pages. The Table A4-1 list of license renewal commitments has been updated to (1) incorporate editorial enhancements, (2) delete the commitments that have been described in previous submittals as being completed, and (3) delete the commitments for subsequently completed enhancements for the following programs:* Quality Assurance Program (Commitment No. 2, LRA Al and B1.3)" Fire Protection Program (Commitment No. 14, LRA Al.12 and B2.1.12)In addition, the following commitments are being revised:* Commitment No. 14 in Table A4-1 for the fire protection program (LRA Al.12 and B2.1.12) has been revised to state-that prior to the period of extended operation, procedures will be enhanced to perform the testing of the Electro-Thermal Links and functional testing of the halon and CO 2 dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the period of extended operation.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway Comanche Peak

• Diablo Canyon Palo Verde -San Onofre -South Texas -Wolf Creek ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Updated License Renewal Application Commitment List, and License Renewal Application Amendment No. 20 Page 2 Commitment No. 20 in Table A4-1 for the buried piping and tanks program (LRA Al.18 and B2.1.18) has been expanded to include additional commitments that will strengthen the buried piping and tanks program.Corresponding updates,to the LRA Appendix A and Appendix B sections for these programs are provided in LRA Amendment 20 in Enclosures 1 and 2.An enhancement to LRA Section 3.3.2.2.4.1 for stainless steel non-regenerative heat exchanger components is also provided in LRA Amendment 20 in Enclosures 1 and 2.Should you need further information regarding this submittal, please contact Russell A.Stroud, Licensing Section Leader, at (623) 393-5111.I declare under penalty of perjury that the foregoing is true and correct.Executed on 7/2-11/ /V (date)Sincerely, JHH/RAS/GAM

Enclosures:

1-. Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 20,- Clean Pages 2. Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 20 -Markup Pages cc: E. E. Collins Jr. NRC Region IV Regional Administrator J. R. Hall NRC NRR Senior Project Manager L. K. Gibson NRC NRR Project Manager R. I. Treadway NRC Senior Resident Inspector for PVNGS L. M. Regner NRC License Renewal Project Manager G. A. Pick NRC Region IV (electronic)

ENCLOSURE 1 Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 20 -Clean Pages LRA Section Page Nos.3.3.2.2.4.1 3.3-36 A1* A-2 A1.12* A-6 A1.18* A-11, 11A Table A4-1 A-42 thru A-59 B1.3* B-2, 3 B2.1.12* B-45, 46, 47 B2.1.18* B-60, 61, 61A The complete Appendix A and B aging management program sections are provided for reviewer convenience when there is any change to the sections.

Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 20 Source: RAI Non-regenerative Heat Exchanger (LRA 3.3.2.2.4.1)

Response LRA 3.3.2.2, Further Evaluation of Aging Management as Recommended by NUREG-1801, Section 3.3.2.2.4.1, Stainless Steel PWR non-regenerative heat exchanger components exposed to borated water, page 3.3-36, is revised as shown below.3.3.2.2.4 Cracking due to Stress Corrosion Cracking and Cyclic Loading 3.3.2.2.4.1 Stainless steel PWR non-regenerative heat exchanger components exposed to borated water The Water Chemistry program (B2.1.2) and the One-Time Inspection program (B2.1.16) will manage cracking due to stress corrosion cracking and cyclic loading for the stainless steel CVCS letdown (non-regenerative) heat exchanger components exposed to treated borated water. Temperature and radioactivity of the shell-side water are monitored by installed instrumentation.

The One-Time Inspection program (B2.1.16) will select heat exchanger tubes with similar materials and environment, including fluid temperatures, to those of the CVCS letdown (non-regenerative) heat exchanger with consideration for temperatures above the threshold of cracking for stainless steel. The One-Time Inspection program (B2.1.16) will perform eddy-current testing of stainless steel heat exchanger tubes in a borated water environment that is above the threshold temperature for cracking of stainless steel.

Appendix A Updated Final Safety Analysis Report Supplement Al

SUMMARY

DESCRIPTIONS OF AGING MANAGEMENT PROGRAMS The integrated plant assessment and evaluation of time-limited aging analyses (TLAA)identified existing and new aging management programs necessary to provide reasonable assurance that components within the scope of License Renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) for the period of extended operation.

Sections Al and A2 describe the programs and their implementation activities.

Three elements common to all aging management programs discussed in Sections Al and A2 are corrective actions, confirmation process, and administrative controls.

These elements are included in the PVNGS Quality Assurance (QA) Program, which implements the requirements of 10 CFR 50, Appendix B. The PVNGS Quality Assurance Program is applicable to all safety-related and nonsafety-related systems, structures and components that are subject to aging management review activities.

Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-2 Appendix A Updated Final Safety Analysis Report Supplement' A1.12 FIRE PROTECTION The Fire Protection program manages loss of material for fire rated doors, fire dampers, diesel-driven fire pumps, and the halon/C0 2 fire suppression systems, cracking, spalling, and loss of material for fire barrier walls, ceilings, and floors, and hardness and shrinkage due to weathering of fire barrier penetration seals. Periodic visual inspections of fire barrier penetration seals, fire dampers, fire barrier walls, ceilings and floors, and periodic visual inspections and functional tests of fire-rated doors manage aging. Periodic testing of the diesel-driven fire pumps ensures that there, is no loss of function due to aging of diesel fuel supply lines. Drop tests are performed on 10 percent of fire dampers on an 18 month basis to manage aging. Visual inspections manage aging of fire-rated doors every 18 months to verify the integrity of door surfaces and for clearances to detect aging of the fire doors. A visual inspection and function test of the halon and C02 fire suppression systems every 18 months (along with the destructive testing of the Electro-Thermal Links (ETLs) and functional testing of the dampers which are both performed every 54 months) manages aging. Ten percent of each type of penetration seal is visually inspected at least once every 18 months. Fire barrier walls, ceilings, and floors including coatings and wraps are visually inspected at least once every 18 months.Prior to the period of extended operation procedures will be enhanced to perform the testing of the Electro-Thermal Links (ETLs) and functional testing of the halon and C02 dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the period of extended operation.

Palo Verde Nuclear Generating Station License Renewal Application Page A-6 Appendix A Updated Final Safety Analysis Report Supplement A1.18 BURIED PIPING AND TANKS INSPECTION The Buried Piping and Tanks Inspection program manages loss of material of buried components in the chemical and volume control, condensate storage and transfer, diesel fuel storage and transfer, domestic water, fire protection, SBOG fuel system, service gas and essential spray ponds systems. Visual inspections monitor the condition of protective coatings and wrappings found on carbon steel, gray cast iron or ductile iron components and assess the condition of stainless steel components with no protective coatings or wraps. The program includes opportunistic inspection of buried piping and tanks as they are excavated or on a planned basis if opportunistic inspections have not occurred.The Buried Piping and Tanks Inspection program is a new program that will be implemented prior to the period of extended of operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.Within the ten year period prior to entering the period of extended operation an opportunistic or planned inspection of buried tanks at the Palo Verde site will be performed.

The visual inspections noted below of piping in a soil environment within the scope of license renewal will be conducted within the ten-year period prior to entering the period of extended operation, and during each ten year period after entering the period of extended operation.

Each inspection will:* select accessible locations where degradation is expected to be high;* excavate and visually inspect the circumference of the pipe; and* examine at least ten feet of pipe.a. Metallic Piping not Cathodically-Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems: o Chemical and Volume Control (CH), o Condensate Transfer and Storage (CT), and o Fire Protection (FP).b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit.Palo Verde Nuclear Generating Station Amendment 20 Page A-11 License Renewal Application Appendix A.Updated Final Safety Analysis Report Supplement

c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.Prior to the period of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE)cathodic protection system surveys are performed at least annually.Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-1 1A Appendix A Updated Final Safety Analysis Report Supplement The summary descriptions of aging management programs, time-limited aging analyses, and license renewal commitments contained in LRA Appendix A, "Updated Final Safety Analysis Supplement," as required by 10 CFR 54.21(d), will be incorporated in the Updated Final Safety Analysis Report for PVNGS Units 1, 2, and 3 in the next update required by 10 CFR 50.71 (e) following the issuance of the renewed operating licenses.(RCTSAI 3247244)The next 10 CFR 50.71 (e) UFSAR update following issuance of the renewed operating licenses.2 Existing Quality Assurance Program is credited for license renewal. Al Ongoing (RCTSAI 3246887) B1.3 Summary Descriptions Of Aging Management 3 Existing ASME Section Xl Inservice Inspection, Subsections IWB, IWC, A1.1 Ongoing and IWD program is credited for license renewal. B2.1.1 (RCTSAI 3246890) ASME Section Xl Inservice Inspection, Subsections IWB, IWC, AND IWD 4 Existing Water Chemistry program is credited for license renewal. A1.2 Ongoing (RCTSAI 3246891).

B2.1.2 Water Chemistry 5 Existing Reactor Head Closure Studs program is credited for license A13 Ongoing renewal. B2.1.3 (RCTSAI 3246892) Reactor Head Closure Studs 6 Existing Boric Acid Corrosion program is credited for license renewal. A1.4 Ongoing (RCTSAI 3246893) B2.1.4 Boric Acid Corrosion Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-42 Appendix A Updated Final Safety Analysis Report Supplement Existing Nickel-Alloy Penetration Nozzles Welded to The Upper R Vessel Ciosure Heads of Pressurized Water Reactors program is credited for license renewal.(RCTSAI 3246894)A1.5 B2.1.5 Nickel-Alloy Penetration Nozzles Welded to The Upper Reactor Vessel Closure Heads of Pressurized Water Reactors 8 Existing Flow-Accelerated Corrosion program is credited for license A1.6' Ongoing renewal. B2.1.6 (RCTSAI 3246895) Flow-Accelerated Corrosion 9 Existing Bolting Integrity program is credited for license renewal. A1.7 Ongoing (RCTSAI 3246896) B2.1.7 Bolting Integrity 10 Existing Steam Generator Tube Integrity program is credited for license A1.8 Ongoing renewal, B2.1.8 (RCTSAI 3246897) Steam Generator Tube Integrity 11 Existing Open-Cycle Cooling Water System program is credited for A1.9 Prior to the period of license renewal, AND B2.1.9 extended operation 1 Prior to the period of extended operation, the program will be enhanced Open-Cycle Cooling to Water System clarify guidance in the conduct of piping inspections using NDE techniques and related acceptance criteria.(RCTSAI 3246898)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-43 Appendix A Updated Final Safety Analysis Report Supplement Existing uloseo-uycie L;ooling water bystem program is credited Tor license renewal, AND Prior to the period of extended operation, procedures will be enhanced to incorporate the guidance of EPRI TR-1 07396 with respect to water chemistry control for frequency of sampling and analysis, normal operating limits, action level concentrations, and times for implementing corrective actions upon attainment of action levels.(RCTSAI 3246899)B2.1.10 Closed-Cycle Cooling Water System'rior to me perioa OT extended operation 1.13 Existing Inspection Of Overhead Heavy Load And Light Load (Related To A1.11 Prior to the period of Refueling)

Handling Systems program is credited for license renewal, B2.1.11 extended operation 1.AND Inspection Of Prior to the period of extended operation, procedures will be enhanced to Overhead Heavy Load inspect for loss of material due to corrosion or rail wear. And Light Load (RCTSAI 3246900) (Related To Refueling)

Handling Systems 14 Existing Fire Protection program is credited for license renewal, AND A1.12 Prior to the period of.Prior to the period of extended operation procedures will be enhanced to B2.1.12 extended operation'.

perform the testing of the Electro-Thermal Links (ETLs) and functional Fire Protection testing of the halon and CO 2 dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the period of extended operation.(RCTSAI 3246901)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-44 Appendix A Updated Final Safety Analysis Report Supplement TnhIgn 6A4-- I if-acn PionoWnI flnMMitjfm~tQ 15 Existing Fire Water System program is credited for license renewal, AND Prior to the period of extended operation, the following enhancements will be implemented:

• Specific procedures will be enhanced to include review and approval requirements under the Nuclear Administrative Technical Manual (NATM).* Procedures will be enhanced to be consistent with the current code of record or NFPA 25 2002 Edition.* Procedures will be enhanced to field service test a representative sample or replace sprinklers prior to 50 years in service and test thereafter every 10 years to ensure that signs of degradation are detected in a timely manner.* Procedures will be enhanced to be consistent with NFPA 25 Section 7.3.2.1, 7.3.2.2, 7.3.2.3, and 7.3.2.4.(RCTSAI 3246902)A1.13 B2.1.13 Fire Water System Prior to the period of extended operation'.

16 Existing Fuel Oil Chemistry program is credited for license renewal, AND Prior to the period of extended operation:

• Procedures will be enhanced to extend the scope of the program to include the SBOG fuel oil storage tank and SBOG skid fuel tanks.* Procedures will be enhanced to include ten-year periodic draining, cleaning, and inspections on the diesel-driven fire pump day tanks, the SBOG fuel oil storage tank, and SBOG skid fuel tanks.* Ultrasonic testing (UT) or pulsed eddy current (PEC) thickness examination will be conducted to detect corrosion-related wall thinning if degradation is found during the visual inspections and once on the tank bottoms for the EDG fuel oil storage tanks, EDG fuel oil day tanks, diesel-driven fire pump day tanks, SBOG fuel oil storage tank, and SBOG skid fuel tanks. The onetime UT or PEC examination on the tank bottoms will be performed before the period of extended operation.(RCTSAI 3246903)A1.14 B2.1.14 Fuel Oil Chemistry Prior to the period of extended operation 1.Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-45 Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item 1Commritrnent~

LRA Section Implementation No.~ Schedule~17 Existing Reactor Vessel Surveillance program is credited for license A1.15 Prior to the period of renewal, AND B2.1.15 extended operation 1.Prior to the period of extended operation:

Reactor Vessel" The schedule will be revised to withdraw the next capsule at the Surveillance equivalent clad-base metal exposure of approximately 54 EFPY expected for the 60-year period of operation, and to withdraw remaining standby capsules at equivalent clad-base metal exposures not exceeding the 72 EFPY expected for a possible 80-year second period of extended operation.

This withdrawal schedule is in accordance with NUREG-1801,Section XI.M31, item 6, and with the ASTM E 185-82 criterion which states that capsules may be removed when the capsule neutron fluence is between one and two times the limiting fluence calculated for the vessel at the end of expected life.This schedule change must be approved by the NRC, as required by 10 CFR 50 Appendix H." If left in the reactor beyond the presently-scheduled withdrawal, the next scheduled surveillance capsule in each unit will reach a clad-base metal 54 EFPY equivalent at about 40 actual operating EFPY (40, 39, and 42 actual EFPY in Units 1, 2, and 3, respectively)." Procedures will be enhanced to identify the withdrawal of the remaining standby capsules at 72 EFPY, at about 50 to 54 actual operating EFPY, near the end of the extended licensed operating period. The need to monitor vessel fluence following removal of the remaining standby capsules, and ex-vessel or in-vessel methods, will be addressed prior to removing the remaining capsules.(RCTSAI 3246904)Palo Verde Nuclear Generating Station Amendment 20 Page A-46 License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement The One-Time Inspection program conducts one-time inspections of plant system piping and components to verify the effectiveness of the Water Chemistry program (Al.2), Fuel Oil Chemistry program (A1.14), and Lubricating Oil Analysis program (Al.23). The aging effects to be evaluated by the One-Time Inspection program are loss of material, cracking, and reduction of heat transfer.(RCTSAIs 3246906 [U 1; 3247258 [U21; 3247259 [U31)A1.16 B2.1.16 One-Time Inspection Within the ten year period prior to the period of extended operation 1.19 The Selective Leaching of Materials program is a new program that will A1.17 Within the ten year be implemented prior to the period of extended operation.

Industry and B2.1.17 period prior to the plant-specific operating experience wili be evaluated in the deveiopment Selective Leaching Of period of extended and implementation of this program. Materials operation 1.(RCTSAIs 3246908 [Ul]; 3247260 [U2]; 3247261 [U3])20 The Buried Piping and Tanks Inspection program is a new program that A1.18 Perform the buried will be implemented prior to the period of extended operation.

B2.1.18 piping and tanks Buried Piping And inspections within the Within the ten year period prior to entering the period of extended Tanks Inspection ten year period prior operation an opportunistic or planned inspection of buried tanks at the to the period of Palo Verde site will be performed.

extended operation 1.The visual inspections noted below of piping in a soil environment within AND the scope of license renewal will be conducted within the ten-year period prior to entering the period of extended operation, and during each ten Perform the buried year period after entering the period of extended operation.

Each piping inspections inspection will: during each ten year period after entering" select accessible locations where degradation is expected to the period of be high; extended operation.

• excavate and visually inspect the circumference of the pipe;and AND" examine at least ten feet of pipe.Implement the___ a. Metallic Piping not Cathodically-Protected additional Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-47 Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Itmj Comimitment~

LRA Sectlio Implementation No. Scedl At least two excavations and visual inspections of stainless steel enhancements to the piping will be conducted in each unit. Stainless steel piping within buried piping and the scope of license renewal exists in the following systems: tanks inspection o Chemical and Volume Control (CH), program prior to the o Condensate Transfer and Storage (CT), and period of operation 1.o Fire Protection (FP).b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit.c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.Prior to the period of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE) cathodic protection system surveys are performed at least annually.(RCTSAIs 3246909 [U1]; 3247263 [U2]; 3247264 [U3])21 The One-Time Inspection of ASME Code Class 1 Small-Bore Piping A1.19 Prior to the period of program is a new program that will be implemented prior to the period of B2.1e19 extended operation.

extended operation.

Industry and plant-specific operating experience will One-Time Inspection be evaluated in the development and implementation of this program. of ASME Code Class 1 (RCTSAIs 3246910 [U_1]; 3247265 [U2]; 3247266 [U3]) Small-Bore Piping Palo Verde Nuclear Generating Station Amendment 20 Page A-48 License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement I ne txternai ,jurtaces monitoring i-rogram is a new program tnat will De implemented prior to the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.(RCTSAIs 3246911 [Ul]; 3247272 [U2]; 3247273 [U3])A1 .ZU B2.1.20 External Surfaces Monitoring Program nrior to me perioa OT extended operation 1.23 APS will: A. Reactor Coolant System Nickel Alloy Pressure Boundary Components Implement applicable (1) NRC Orders, Bulletins and Generic Letters associated with nickel alloys and (2) staff-accepted industry guidelines, (3) participate in the industry initiatives, such as owners group programs and the EPRI Materials Reliability Program, for managing aging effects associated with nickel alloys, (4) upon completion of these programs, but not less than 24 months before entering the period of extended operation, APS will submit an inspection plan for reactor coolant system nickel alloy pressure boundary components to the NRC for review and approval, and B. Reactor Vessel Internals (1) Participate in the industry programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, APS will submit an inspection plan for reactor internals to the NRC for review and approval.C. Pressurizer Spray Heads Comply with applicable NRC Orders and implement applicable (1)Bulletins and Generic Letters, and (2) staff-accepted industry guidelines.(RCTSAIs 3246912 [U1]; 3247274 [U2]; 3247276 [U3])A1.21 B2.1.21 Reactor Coolant System Supplement 3.1.2.2.16.2 Pressurizer spray head cracking Not less than 24 months prior to the period of extended operation 1.Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-49 Appendix A Updated Final Safety Analysis Report Supplement The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that will be implemented prior to the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.(RCTSAIs 3246914 [U1]; 3247277 [U2]; 3247278 [U3])A1.22 B2.1.22 Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components Prior to the period ot extended operation'.

25 Existing Lubricating Oil Analysis program is credited for license renewal. A1.23 Ongoing (RCTSAI 3246915) B2.1.23 Lubricating Oil Analysis 26 The Electrical Cables and Connections Not Subject to 10 CFR 50.49 A1.24 Prior to the period of Environmental Qualification Requirements program is a new program that B2.1.24 extended operation'.

will be implemented prior to the period of extended operation.

Industry Electrical Cables And and plant-specific operating experience will be evaluated in the Connections Not development and implementation of this program. Subject to 10 CFR ,(RCTSAI 3246917) 50.49 Environmental Qualification Requirements 27 Existing Electrical Cables And Connections Not Subject To 10 CFR 50.49 A1.25 Prior to the period of Environmental Qualification Requirements Used In Instrumentation B2.1.25 extended operation'.

Circuits program is credited for license renewal , AND Electrical Cables And Prior to the period of extended operation:

Connections Not* Procedures will be enhanced to identify license renewal scope, Subject To 10 CFR require cable testing of ex-core neutron monitoring cables, require an 50.49 Environmental evaluation of the calibration results for non-EQ area radiation Qualification monitors, and require acceptance criteria for cable testing be Requirements Used In established based on the type of cable and type of test performed.

Instrumentation (RCTSAI 3246919) Circuits Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-50 Appendix A Updated Final Safety Analysis Report Supplement I nl{t !F1dnaU Z51Ul iVlU IV umrr i VUILd ,t U.adUlt P .UL OUDJeCL 1 IU l- rm U ou.-,+EQ Requirements program is a new program that will be implemented prior to the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.' I .LO B2.1.26 Inaccessible Medium Voltage Cables Not Subject To 10 CFR 50.49 Environmental riUr LU LH[U [PrIUu U1 extended operation 1.(RCTSAI 3246920)Qualification Reauirements 29 Existing ASME Section XI, Subsection IWE program is credited for A1.27 Ongoing license renewal. B2.1.27 (RCTSAI 3246921) ASME Section XI, Subsection IWE 30 Existing ASME Section XI, Subsection IWL program is credited for A1.28 Ongoing license renewal. B2.1.28 (RCTSAI 3246922) ASME Section Xl, Subsection IWL 31 Existing ASME Section XI, Subsection IWF program is credited for A1.29 Ongoing license renewal. B2.1.29 (RCTSAI 3246923) ASME Section XI, Subsection IWF 32 Existing 10 CFR 50, Appendix J program is credited for license renewal. A1.30 Ongoing (RCTSAI 3246924) B2.1.30 10 CFR 50, Appendix J 33 Existing Masonry Wall Program is credited for license renewal, AND A1.31 Prior to the period of Prior to the period of extended operation, procedures will be enhanced to B2.1.31 extended operation 1.specify ACI 349.3R-96 as the reference for qualification of personnel to Masonry Wall Program inspect structures under the Masonry Wall Program, which is part of the Structures Monitoring Program.(RCTSAI 3246926)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-51 Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments ItmCommnitment LRA Section1 Implementation No. Scheduile 34 Existing Structures Monitoring Program is credited for license renewal, A1.32 Prior to the period of AND B2.1.32 extended operation'.

Prior to the period of extended operation:

Structures Monitoring

• The Structures Monitoring Program will be enhanced to specify ACI Program 349.3R-96 as the reference for qualification of personnel to inspect structures under the Structures Monitoring Program.* For structures within the scope of license renewal, the Structures Monitoring Program will be enhanced to establish the frequency of inspection for each unit at a 5 year interval, with the exception of exterior surfaces of the following nonsafety-related structures, below-grade structures, and structures within a controfled interior environment, which will be inspected at an interval of 10 years:* Fire Pump House (Yard Structures)

• Radwaste Building* Station Blackout Generator Structures

• Turbine Building* Non-Safety Related Tank Foundations and Shells* Non-Safety Related Transformer Foundations and Electrical Structures

• The Structures Monitoring Program will be enhanced to quantify the acceptance criteria and critical parameters for monitoring degradation, and to provide guidance for identifying unacceptable conditions requiring further technical evaluation or corrective action.Procedures will also be enhanced to incorporate applicable industry codes, standards and guidelines for acceptance criteria.(RCTSAI 3246927)Palo Verde Nuclear Generating Station Amendment 20 Page A-52 License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement Existing RG 1.127, Inspection Of Water-Control Structures Associated With Nuclear Power Plants program is credited for license renewal, AND Prior to the period of extended operation, procedures will be enhanced to specify that the essential spray ponds inspections include concrete below the water level.(RCTSAI 3246928)A1.33 B2.1.33 RG 1.127, Inspection Of Water-Control Structures Associated With Nuclear Power Plants Prior to the period ot extended operation'.

36 Existing Nickel Alloy Aging Management Program is credited for license A1.34 Ongoing renewal. B2.1.34 (RCTSAI 3260208) Nickel Alloy Aging Management Program 37 The Electrical Cable Connections Not Subject to 10 CFR 50.49 A1.35 Prior to the period of Environmental Qualification Requirements program is a new program that B2.1.35 extended operation'.

will be implemented prior to the period of extended operation.

industry Electrical Cable and plant-specific operating experience will be evaluated in the Connections Not development and implementation of this program. Subject To 10 CFR (RCTSAIs 3246930 [U1]; 3247228 [U2]; 3247231 [U3]) 50.49 environmental qualification requirements 38 The Metal Enclosed Bus program is a new program and will be A1.36 Prior to the period of completed before the period of extended operation and once every 10 B2.1.36 extended operation years thereafter.

Industry and plant-specific operating experience will be Metal Enclosed Bus and once every ten evaluated in the development and implementation of this program. years thereafter.(RCTSAIs 3246932 [Ul]; 3247220 [U2]; 3247221 [U3])39 No later than two years prior to the period of extended operation, the 4.3.1 No later than two following enhancements will be implemented Fatigue Aging years prior to the* Cumulative usage factor tracking will be implemented for Management Program period of extended NUREG/CR-6260 locations not monitored by cycle counting (the A2.1 operation'.

reactor vessel shell and lower head (juncture) location will be B3.1 monitored by cycle counting).

For PVNGS locations identified in Metal Fatigue of NUREG/CR-6260 and monitored by CUF, fatigue usage factor Reactor Coolant action limits will be required for including effects of the reactor Pressure Boundary Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-53 Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Itemn~ ( C -oimniitment~

~LRA Section< Implemnentation~

No. I J Schedtule coolant environment.

o The Metal Fatigue of Reactor Coolant Pressure Boundary program will be enhanced to include a computerized program to track and manage both cycle counting and fatigue usage factor.FatiguePro will be used for cycle counting and cycle-based fatigue (CBF) monitoring methods. FatiguePro is an EPRI licensed product.o The enhanced Metal Fatigue of Reactor Coolant Pressure Boundary program will monitor plant transients as required by PVNGS Technical Specification 5.5.5. Cumulative usage factors (CUFs) will be calculated for a subset of ASME III Class 1 reactor coolant pressure boundary vessel and piping locations, and component locations with Class 1 analyses.

The following methods will be used: 1) The Metal Fatigue of Reactor Coolant Pressure Boundary program will be enhanced to use cycle based fatigue (CBF)and stress based fatigue (SBF) CUF calculations to monitor fatigue. FatiguePro will be used for cycle counting and cycle-based fatigue (CBF) monitoring methods. FatiguePro is an EPRI licensed product.2) The SBF method will use a fatigue monitoring software program that incorporates a three-dimensional, six-component stress tensor method meeting ASME III NB-3200 requirements.

• The enhanced Metal Fatigue of Reactor Coolant Pressure Boundary program will provide action limits on cycles and on CUF that will initiate corrective actions before the licensing basis limits on fatigue effects at any location are exceeded.o In order to ensure sufficient cycle count margin to accommodate occurrence of a low-probability transient, corrective actions must be taken before the remaining number of allowable occurrences for any specified Palo Verde Nuclear Generating Station Amendment 20 Page A-54 License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement transient becomes less than 1.o CUF action limits will be established to require corrective action when the calculated CUF (from cycle-based or stress-based monitoring) for any monitored location is projected to reach 1.0 within the next 2 or 3 operating cycles. In order to ensure sufficient margin to accommodate occurrence of a low-probability transient, corrective actions will be taken while there is still sufficient margin to accommodate at least one occurrence of the worst-case design transient event (i.e., with the highest fatigue usage per event cycle).(RCTSAI 3246934)40 Existing Environmental Qualification program is credited for license A2.2 Prior to the period of renewal, AND B3.2 extended operation'.

maintaining qualification through the extended license renewal period Environmental requires that existing EQ evaluations (EEQDFs) be re-evaluated.

Qualification (EQ) Of.(RCTSAI 3246935) Electrical Components Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-55 Appendix A Updated Final Safety Analysis Report Supplement Existing Concrete Containment Tendon Prestress program is credited for license renewal, AND* The program will be enhancedto continue to compare regression analysis trend lines of the individual lift-off values of tendons surveyed to date, in each of the vertical and hoop tendon groups, with the MRV and PLL for each tendon group, to the end of the licensed operating period, and to take appropriate corrective actions if future values indicated by the regression analysis trend line drop below the PLL or MRV. The regression analyses will be updated for tendons of the affected unit and for a combined data set of all three units following each inspection of an individual unit.* Prior to the period of extended operation, procedures will be enhanced to require an update of the regression analysis for each tendon group of each unit, and of the joint regression of data from all three units, after every tendon surveillance.

The documents will invoke and describe regression analysis methods used to construct the lift-off trend lines, including the use of individual tendon data in accordance with Information Notice (IN) 99-10, "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments."" The Tendon Integrity test procedure will be revised to extend the list of surveillance tendons to include random samples for the year 45 and 55 surveillances.(RCTSAI 3246937)B3.3 Concrete Containment Tendon Prestress Prior to the period of extended operation 1.4.5 Concrete Containment Tendon Prestress I 42 APS will confirm the RCS Pressure-Temperature limits basis for 54 EFPY A3.1.3 Prior to operation prior to operation beyond 32 EFPY and will update documents in Pressure-Temperature beyond 32 EFPY 1.accordance with the provisions of 10 CFR 50.59. (RCTSAI 3246939) Limits 43 Completed (RCTSAI 3246941)44 Completed (RCTSAI 3253459)45 See Item No. 46 (RCTSAI 3246943_1 Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-56 Appendix A Updated Final Safety Analysis Report Supplement An extension of ISI Relief Request 31, Revision 1 authorizatior requested for the period of extended operation, supported by a continuation of the cold shutdown time monitoring program.(RCTSAI 3246945)Fatigue Crack Growth and Fracture Mechanics Stability Analyses of Half-Nozzle Repairs to Alloy 600 Material in Reactor Coolant Hot Legs; Absence of a TLAA for Supporting Corrosion Analyses Prior to the period of extended operation 1.47 Once the ground surface is made less permeable and ambient monitoring Environmental Report 12/31/10 is sufficient to characterize subsurface water quality, a [tritiated water] 2.3 remediation plan will be implemented.(RCTSAI 3246946)48 New Evaporation Pond No. 3 is currently under construction and is being Environmental Report 12/31/15 built using a Best Available Demonstrated Control Technology (BADCT), 3.1.2 a geosynthetic clay liner, with two overlaying HDPE liners, including a leachate collection and recovery system, plus soil cement side armoring, including a leak detection system. Following that, the existing liner in Evaporation Pond No. 2 will be replaced with the same BADCT liner system. This liner is approaching the end of its useful life. Following that, the existing liner in Evaporation Pond Number 1 will be replaced with the same BADCT liner system.(RCTSAI: 3246947)49 APS commits to implement SAMAs 6, 17 and,23 prior to the period of Environmental Report Prior to the period of extended operation.

D.8 extended operation 1.(RCTSAI 3246952)Palo Verde Nuclear Generating Station License Renewal Application Amendment20 Page A-57 Appendix A Updated Final Safety Analysis Report Supplement The Fuse Holder program is a new program that will be implemented prior to the period of extended operation and once every 10 years thereafter.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program (RCTSAI 3409443)A1.37 B2.1.37 Fuse Holder Prior to the period ot extended operation and once every 10 years thereafter.

51 The original Unit 3 reactor pressure vessel (RPV) head is planned to be B2.1.34 12/31/10 replaced during the fall refueling outage in 2010. All components Nickel Alloy Aging penetrating the new heads and welds including the head vent will be Management Program replaced with Alloy 690. The Unit 2 RPV head was replaced during 2R15 outage in fall 2009, and the Unit I RPV head was replaced during 1 R!5 in spring 2010.(RCTSAI 3410460)52 APS will consider SAMA 8 for potential implementation.

Follow-up Response to Prior to the period of (RCTSAI 3420542) SAMA RAI (letter no. extended operation 1.102-06121, dated January 13, 2010)53 Completed (RCTSAI 3429933)54 By August 30, 2010, APS will ensure that that the abandoned Response to RAI 2.1- 8/30/10 containment spray chemical addition tanks and associated piping 03, Issue (2), in APS components in PVNGS Units 1, 2, and 3 are drained to preclude any letter no. 102-06162, spatial interactions with safety related components.

dated 4/2/10 (RCTSAI 3443855)55 The transient in UFSAR Table 3.9-1 Sheet No. 9 Item No. I.E.1 .b, and 4.3.1 8/25/10 Sheet No. 18, Item No. III.A. 1.f, "Standby to SI hot leg injection check Fatigue Aging valve stroke test to standby (using the HPSI pump)," will be added to the Management Program cycle counting surveillance procedure 73ST-9RC02 by August 25, 2010. (Table 4.3-2, Row No.(RCTSAI 3469024).

25)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-58 Appendix A Updated Final Safety Analysis Report Supplement The spray pond wall rework/repair methods are currently being determined, and the rework/repair is planned to begin in 2011. As Unit 1 spray ponds have the most degradation, work is planned to start there followed by Units 2 and 3. It is expected that the work will be completed in all three units in 2015.(RCTSAI 3484623)Follow-up Response to RAI B2.1.33-2 (letter no.102-06205, dated June 21, 2010)57 No later than two years prior to the period of extended operation, APS will Response to RAI RAI No later than two confirm the conservatism of the Fen value of 1.49 using the methods 4.3-6 (letter no. years prior to the specified in NUREG/CR-6909, and will use the Fen calculated using the 102-06210, dated period of extended NUREG/CR-6909 methods if it is more conservative than the 1.49 value. June 29, 2010) operation'.(RCTSAI 3488220)58 No later than two years prior to the period of extended operation, APS will Response to RAI RAI No later than two perform a reanalysis of the pressurizer heater penetrations to consider 4.3-6 (letter no. years prior to the EAF effects using the formulas and methodology given in NUREG/CR-102-06210, dated period of extended 6909. June 29, 2010) operation 1.(RCTSAI 3488223)(1) "Prior to period of extended operation," "prior to operation beyond 32 EFPY," and "prior to the end of the current licensed operating period," is prior to the following PVNGS Operating License expiration dates: Unit 1: June 1, 2025; Unit 2: April 24, 2026; Unit 3: November 25, 2027.Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-59 Appendix B AGING MANAGEMENT PROGRAMS B1.3 QUALITY ASSURANCE PROGRAM AND ADMINISTRATIVE CONTROLS The PVNGS Quality Assurance Program implements the requirements of 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants," and is consistent with the summary provided in Appendix A.2 of NUREG-1800 and the Appendix, "Quality Assurance for Aging Management Programs" of NUREG-1 801. The PVNGS Quality Assurance Program includes the elements of corrective action, confirmation process, and administrative controls.

The PVNGS Quality Assurance Program is applicable to all safety-related and nonsafety-related systems, structures, and components (SSCs) that are subject to aging management activities.

Each of these three elements is applicable as follows: Corrective Action PVNGS applies its corrective action process to safety-related and, after enhancement, nonsafety-related systems, structures, and components that are subject to aging management.

Corrective action process procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants. Conditions adverse to quality (such as failures, malfunctions, deviations, defective material and equipment, and nonconformances) are promptly identified and corrected.

Significant conditions adverse to quality (such as failures, malfunctions, deviations, defective material and equipment, and nonconformances) are promptly identified and corrected.

In the case of significant conditions adverse to quality, measures are implemented to ensure that the cause is determined and that corrective action is taken to preclude repetition.

In addition, the root cause of the significant condition adverse to quality and the corrective actions implemented are documented and reported to appropriate levels of management.

Confirmation Process The PVNGS Quality Assurance Program requires that measures be taken to preclude repetition of significant conditions adverse to quality. These measures include actions to verify effective implementation of corrective actions.Plant procedures include provisions for timely evaluation of adverse conditions and implementation of any corrective actions required, including root cause determinations and prevention of recurrence where appropriate (e.g., significant conditions adverse to quality).These procedures provide for tracking, coordinating, monitoring, reviewing, verifying, validating, and approving corrective actions, and to ensure corrective actions have been effectively implemented.

The corrective action process is also monitored for potentially adverse trends. Identification of a potentially adverse trend due to recurring or repetitive unacceptable conditions will result in the initiation of a corrective action document.Follow-up inspections required by the confirmation process are documented in accordance with the corrective action process. The corrective action process constitutes the confirmation process for aging management programs and activities.

The same 10 CFR 50 Palo Verde Nuclear Generating Station Amendment 20 Page B-2 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS Appendix B corrective actions and confirmation process applies to nonconforming systems, structures, and components subject to aging management review.Administrative Controls PVNGS administrative controls require formal procedures and other forms of written instruction for the activities performed under the programs credited for managing aging.These PVNGS procedures contain objectives, program scope, responsibilities, methods for implementation, and acceptance criteria.Enhancements None Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page B-3 Appendix B AGING MANAGEMENT PROGRAMS B2.1.12 Fire Protection Program Description The Fire Protection program manages loss of material for fire rated doors, fire dampers, diesel-driven fire pumps, and the C0 2 and halon fire suppression systems, cracking, spalling, and loss of material for fire barrier walls, ceilings, and floors, and hardness and shrinkage due to weathering of fire barrier penetration seals. Periodic visual inspections of fire barrier penetration seals, fire dampers, fire barrier walls, ceilings and floors, and periodic visual inspections and functional tests of fire-rated floors are performed to ensure that they can perform their intended function.The Fire Protection program manages aging by a visual inspection on ten percent of each type of penetration seal at least once every 18 months. This sample set method ensures that each penetration seal is inspected at least once every 15 years.The Fire Protection program manages aging by a visual inspection every 18 months of the fire barrier walls, ceilings, and floors, including coating and wraps of Thermo-lag enclosures, examining for any signs of aging such as cracking,.

spalling, and loss of material.The Fire Protection program manages aging by drop testing on ten percent of all accessible fire dampers on an 18 month basis.The Fire Protection program manages aging by performing visual inspections every 18 months on fire-rated doors to verify the integrity of door surfaces and for clearances to detect aging of the fire doors prior to the loss of intended function.The diesel-driven fire pumps are under observation during performance tests such as flow tests, start/run tests for detecting any aging of the fuel supply line. The fuel oil supply line is also managed by the Fuel Oil Chemistry program (B2.1.14) and External Surface Monitoring Program (82.1.20).

A visual inspection and function test of the halon and CO 2 fire suppression systems is perforrned every 18 months (with the exception of destructive testing of the Electro-Thermal Links (ETLs) and functional testing of the dampers which are performed every 54 months).NUREG-1801 Consistency The Fire Protection program is an existing program that, following enhancement, will be consistent with NUREG-1801,Section XI.M26, "Fire Protection," with an exception.

Exceptions to NUREG-1801 Program Elements Affected Parameters Monitored or Inspected

-Element 3 and Detection of Aging Effects -Element 4 NUREG-1801 recommends a visual inspection and function test of the halon and CO 2 systems every six months. The PVNGS procedures for visual inspections and function testing of the halon and CO 2 fire suppression systems are performed every 18 months Palo Verde Nuclear Generating Station Amendment 20 Page B-45 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS (excluding destructive testing of the Electro-Thermal Links (ETLs) and functional testing of the dampers, which are both performed every 54 months per TSR 3.11.103.5, 3.11.103.6, 3.11.106.5 and 3.11.106.6) per Technical Requirements Manual Surveillance Requirement (TSR) 3.11.106.4 and 3.11.103.4, respectively.

These functional tests will also identify any mechanical damage of the halon and CO 2 fire suppression system that prevents the system from performing its intended function.

With respect to the 54 month destructive testing of the Electro-Thermal Links (ETLs), PVNGS has performed an engineering analysis, consistent with the methodology described within EPRI Technical Report 1006756 "Fire Protection Equipment Surveillance Optimization and Maintenance Guide 2003" to extend the frequency of the test so that the confidence of functionality obtained by successful completion of the test is aligned with reliability and logistical concerns of the test. The calculation indicates that a full functional test every six years of the dampers actuated by ETLs will maintain a 95% success rate assuming the same amount of failures as have occurred in the last 10 years and adjusting for uncertainty at the 99% level. The selection of a testing interval of 54 months, compared to the calculated value of 72 months for 95% success rate, provides an additional margin of protection.

The test frequency is considered sufficient to ensure system availability and operability based on station operating history that indicates no loss of intended function due to aging. A review of the past ten years of operating experience and corrective action documentation has shown no degradation or loss of intended function between test intervals.

Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements: Parameters Monitored or Inspected

-Element 3, and Detection of Aging Effects -Element 4 Procedures will be enhanced to perform the testing of the Electro-Thermal Links (ETLs) and functional testing of the halon and CO 2 dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the period of extended operation.

Operating Experience Plant operating experience indicates that there have been instances of Thermo-Lag degradation and cracking.

These portions of affected Thermo-Lag envelopes have been reworked according to PVNGS specification.

PVNGS has also experienced door skin cracks. These have been weld repaired according to specification.

During May of 2005, a fire protection audit was performed by members of APS and other industry representatives.

The audit team observed current conditions and installations of the CO 2 and halon suppression systems during walk-downs of selected fire zones. All systems were found in good condition.

Multiple walkdowns per unit were conducted to examine the current condition of existing fire barriers in the Unit 1 control building, the Unit 2 turbine building, and the Unit 3 auxiliary building.

There was one adverse condition identified in the Unit 3 auxiliary building where copper piping was penetrating the floor barriers.

The audit team found no degraded conditions (e.g., cracks, gouges, holes in material, joint/seal gaps) of installed electrical raceway fire barriers.Palo Verde Nuclear Generating Station Amendment 20 Page B-46 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS In September of 2006, it was discovered that a carbon steel pipe nipple was in need of replacement due to galvanic corrosion and was subsequently replaced.

The nipple was located between a galvanized tee and a brass valve. This event is representative of the PVNGS experience of detecting degradations and leakage in time to take corrective action prior to the loss of intended function.During the 2007 fire protection audit, a concern was raised for the need of a plan to identify fire protection equipment obsolescence issues. Design modifications have been identified to address these issues.Conclusion The continued implementation of the Fire Protection program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page B-47 Appendix B AGING MANAGEMENT PROGRAMS B2.1.18 Buried Piping and Tanks Inspection Program Description The Buried Piping and Tanks Inspection program manages loss of material on external surfaces of buried components in the following systems: chemical and volume control, condensate storage and transfer, diesel fuel storage and transfer, domestic water, fire protection, SBOG fuel system, service gas and essential spray ponds. Opportunistic visual inspections will monitor the condition of protective coatings and wrappings found on carbon steel, gray cast iron or ductile iron components and assess the condition of stainless steel components with no protective coatings or wraps. Any evidence of damaged wrapping or coating defects is an indicator of possible corrosion damage to the external surface of the components.

The Buried Piping and Tanks Inspection program is a new program that will be implemented prior to the period of extended operation.

Within the ten year period prior to entering the period of extended operation an opportunistic or planned inspection of buried tanks at the Palo Verde site will be performed.

The visual inspections noted below of piping in a soil environment within the scope of license renewal will be conducted within the ten-year period prior to entering the period of extended operation, and during each ten year period after entering the period of extended operation.

Each inspection will: " select accessible locations where degradation is expected to be high;* excavate and visually inspect the circumference of the pipe; and* examine at least ten feet of pipe.a. Metallic Piping not Cathodicaily Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems: o Chemical and Volume Control (CH), o Condensate Transfer and Storage (CT), and o Fire Protection (FP).b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit.Palo Verde Nuclear Generating Station Amendment 20 Page B-60 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.Prior to the period of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE)cathodic protection system surveys are performed at least annually.NUREG-1801 Consistency The Buried Piping and Tanks Inspection program is a new program that, when implemented, will be consistent with exception to NUREG-1801,Section XI.M34, "Buried Piping and Tanks Inspection".

Exceptions to NUREG-1801 Program Elements Affected Scope of Program -Element 1 and Acceptance Criteria-Element 6 NUREG-1801,Section XI.M34 scope only includes buried steel piping and components.

However, PVNGS also includes stainless steel in their buried piping program that will be managed as part of this aging management program.Scope of Program -Element 1, Preventive Actions -Element 2, and Acceptance Criteria-Element 6 NUREG-1801,Section XI.M34 relies on preventive measures such as coatings and wrappings.

However, portions of buried stainless steel piping may not be coated or wrapped. Inspections of buried piping that is not wrapped will inspect for loss of material due to general, pitting, crevice, and microbiologically influenced corrosion.

Enhancements None Operating Experience The Buried Piping and Tanks Inspection program is a new program. Degradation of buried components was addressed at PVNGS during an inspection program in September 2002. Observations of this inspection program include: During the past several years, leaks developed in various buried piping segments, which potentially threaten the continuous operation of PVNGS. These leaks collectively indicated a negative trend in the overall integrity of the buried pipe.Palo Verde Nuclear Generating Station Amendment 20 Page B-61 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS Inspection and maintenance activities were implemented in order to address overall integrity of the buried pipe. Determination of system priorities and development of a draft inspection plan for each of the evaluated systems was developed.

The applicable systems with piping installed below grade were evaluated and assigned ranking based on priority.

The majority of these evaluated buried piping systems have very little or no identified potential for degradation.

The majority of the systems evaluated in the inspection program are not within the scope of license renewal. The PVNGS corrective action documentation to date has shown that, for the systems within the scope of license renewal, degradation has been found primarily in the fire protection system. Fire protection system has had localized degradation in excess of the minimum wall requirement of 40% nominal wall thickness.

The designated segments of the degraded ductile iron piping have been replaced by fiberglass reinforced plastic piping. The fire protection system has not experienced a failure that affected the ability of the plant to achieve and maintain safe shutdown in the event of a fire. To date, the actual pipe failures of the underground fire protection system have been isolated and repaired without adversely affecting any fire protection water suppression system.Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.Conclusion The implementation of the Buried Piping and Tanks Inspection program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page B-61A ENCLOSURE 2 Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 20 -Markup Pages Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 20 Source: RAI Non-regenerative Heat Exchanger(LRA 3.3.2.2.4.1)

Response LRA 3.3.2.2, Further Evaluation of Aging Management as Recommended by NUREG-1801, Section 3.3.2.2.4.1, Stainless Steel PWR non-regenerative heat exchanger components exposed to borated water, page 3.3-36, is revised as shown below. Deleted text is shown in strike through and new text is shown underlined.

3.3.2.2.4 Cracking due to Stress Corrosion Cracking and Cyclic Loading 3.3.2.2.4.1 Stainless steel PWR non-regenerative heat exchanger components exposed to borated water The Water Chemistry program (B2.1.2) and the One-Time Inspection program (82.1.16) will manage cracking due to stress corrosion cracking and cyclic loading for the stainless steel CVCS letdown (non-regenerative) heat exchanger components exposed to treated borated water. Temperature and radioactivity of the shell-side water are monitored by installed instrumentation.

The One-Time Inspection program (B2.1.16) is selected in "e'u of eddy current testinqg-oftubes will select heat exchanqer tubes with similar materials and environment, including fluid temperatures, to those of the CVCS letdown (non-regenerative) heat exchanger with consideration for temperatures above the threshold of cracking for stainless steel. The One-Time Inspection program (B2.1.16) will perform eddy-current testing of stainless steel heat exchanger tubes in a borated water environment that is above the threshold temperature for cracking of stainless steel.This position w-s found -ccoptable to thc NRC staff in NUREG 1785, "Safety Evaluation Repor Related to the Liccnsc Renewal ef H. .B. ' R-Gb"RseR -BeEtrOGic Plant, Unit 2".

Appendix A Updated Final Safety Analysis Report Supplement Al

SUMMARY

DESCRIPTIONS OF AGING MANAGEMENT PROGRAMS The integrated plant assessment and evaluation of time-limited aging analyses (TLAA)identified existing and new aging management programs necessary to provide reasonable assurance that components within the scope of License Renewal will continue to perform their intended functions consistent with the current licensing basis (CLB) for the period of extended operation.

Sections Al and A2 describe the programs and their implementation activities.

Three elements common to all aging management programs discussed in Sections Al and A2 are corrective actions, confirmation process, and administrative controls.

These elements are included in the PVNGS Quality Assurance (QA) Program, which implements the requirements of 10 CFR 50, Appendix B. The PVNGS Quality Assurance Program is applicable.

to all safety-related and, aftcr enhanRce.ent, will also be applicable to the nonsafety-related systems, structures and components that are subject to aging management review activities.

Uproceure

-Aill oh to includite thl-o4o no"n-atety related SSG rc-nirin'qinqg m~anageMent RRImn Me sco)pe Of Mnc rvi'S Quality:~s rASUanco 14oram. 1o apaaress lme elemqentS Of corrective actionRs, confirmation process, and adminis~trAtfioP controls, Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-2 Appendix A Updated Final Safety Analysis Report Supplement A1.12 FIRE PROTECTION The Fire Protection program manages loss of material for fire rated doors, fire dampers, diesel-driven fire pumps, and the halon/C0 2 fire suppression systems, cracking, spalling, and loss of material for fire barrier walls, ceilings, and floors, and hardness and shrinkage due to weathering of fire barrier penetration seals. Periodic visual inspections of fire barrier penetration seals, fire dampers, fire barrier walls, ceilings and floors, and periodic visual inspections and functional tests of fire-rated doors manage aging. Periodic testing of the diesel-driven fire pumps ensures that there is no loss of function due to aging. of diesel fuel supply lines. Drop tests are performed on 10 percent of fire dampers on an 18 month basis to manage aging. Visual inspections manage aging of fire-rated doors every 18 months to verify the integrity of door surfaces and for clearances to detect aging of the fire doors. A visual inspection and function test of the halon and CO 2 fire suppression systems every 18 months (along with the destructive testing of the Electro-Thermal Links (ETLs) and functional testing of the dampers which are both performed every 54 months) manages aging. Ten percent of each type of penetration seal is visually inspected at least once every 18 months. Fire barrier walls, ceilings, and floors including coatings and wraps are visually inspected at least once every 18 months.Prior to the period of extended operation procedures will be enhanced to perform the testing of the Electro-Thermal Links (ETLs) and functional testing of the halon and CO2 dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the period of extended operation., the following enhanc.ments will be-.eeRteE..'Procedures will be enhanced to inspect formehnia damage, corros-_ion.

and loss o fT aterial o~f the G02 systemn diSch affe nzzes.e IBO I R I ....I= a f .d=F!F0ocodUros Will 198 ennancoa to state the Eguaiitication requirements for RnSPectng DeR etration seals, fire rated doors, fire barn: BF walls. Gellincis ana flor-S.Palo Verde Nuclear Generating Station License Renewal Application Page A-6 Appendix A Updated Final Safety Analysis Report Supplement A1.18 BURIED PIPING AND TANKS INSPECTION The Buried Piping and Tanks Inspection program manages loss of material of buried components in the chemical and volume control, condensate storage and transfer, diesel fuel storage and transfer, domestic water, fire protection, SBOG fuel system, service gas and essential spray ponds systems. Visual inspections monitor the condition of protective coatings and wrappings found on carbon steel, gray cast iron or ductile iron components and assess the condition of stainless steel components with no protective coatings or wraps. The program includes opportunistic inspection of buried piping and tanks as they are excavated or on a planned basis if opportunistic inspections have not occurred.The Buried Piping and Tanks Inspection program is a new program that will be implemented prior to the period of extended of operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.Within the ten year period prior to entering the period of extended operation an opportunistic or planned inspection of buried tanks at the Palo Verde site will be performed.

Within the ton I.. pe. d prior to entering the period Of extended operation the buried piping inspectin-noted below will be Upn the period ot e~teaded o~perationR the bur~ied piping inspections notod below will be perfore)Fd within ten years. Inldust,'

and plant ,pecific vxperience will be evaluated in the deVelopmnt anRd implementatio-In of this program" The visual inspections noted below of piping in a soil environment within the scope of license renewal will be conducted within the ten-year period prior to entering the period of extended operation, and again within the first-ten ye.1- during each ten year period after entering the period of extended operation.

Each inspection will:* select accessible locations where degradation is expected to be high;* excavate and visually inspect the circumference of the pipe; and o examine at least ten feet of pipe.a. Metallic Piping not Cathodically-Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems: o Chemical and Volume. Control (CH), o Condensate Transfer and Storage (CT), and o Fire Protection (FP).b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit.Palo Verde Nuclear Generating Station Amendment 20 Page A-11 License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement

c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.Prior to the period of extended operation, the Buried Piping and Tanks Inspection pro-gram will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE)cathodic protection system surveys are performed at least annually.Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-1i A Appendix A Updated Final Safety Analysis Report Supplement Section^ A3 [rf the LRA] contains evaluation .um.marie of ToILAAs for the period of extended operation...

These summary descriptions of aging management p am-m programs,-a444 time-limited aging analyses, and license renewal commitments contained in LRA Aooendix A. "Updated The next 10U UFRK 50.71(e) UFSAR update following issuance of the renewed operating licenses.

{E-stimated j61R8 30,2044)Final Safety Analysis Supplement," as required by 10 CFR 54.21 (d), will be incorporated in the Updated Final Safety Analysis Report for PVNGS Units 1, 2, and 3 in the next update required by 10 CFR 50.71(e)following the issuance of the renewed operating licenses in accordance with 10 CFR 50.71(e).(RCTSAI 3247244)2 Pro.edures will be enhanceGP.d.

to_ inc"'ud" those noqsafoty related SSCS Al Prior to the period oe reuiin aRg management within the scope 9f the P2VNSGS Quality 6B1.3 e~tRe~de Assurance Program to addrFes the elements o co rr.ctve actions, Summary Descriptions epe-FatieR 4-Onqoinq confirmation pro.ess, and administrative c.. tro.s. Existing Quality Of Aging Management Assurance Pro-gram is credited for license renewal.(RCTSAI 3246887)3 Existing ASME Section XI Inservice Inspection, Subsections IWB, IWC, A1.1 Ongoing and IWD program is credited for license renewal. B2.1.1 (RCTSAI 3246890) ASME Section XI Inservice Inspection, Subsections IWB, IWC, AND IWD 4 (LRA Amendment

9) A1.2 Ongoing Existing Water Chemistry program is credited for license renewal. B2.1.2 (RCTSAI 3246891).

Water Chemistry 5 Existing Reactor Head Closure Studs program is credited for license A1.3 Ongoing renewal. B2.1.3 (RCTSAI 3246892) Reactor Head Closure Studs 6 Existing Boric Acid Corrosion program is credited for license renewal. Al.4 Ongoing (RCTSAI 3246893) B2.1.4 Boric Acid Corrosion Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-42 Appendix A Updated Final Safety Analysis Report Supplement (LRA Supplement 1)Existing Nickel-Alloy Penetration Nozzles Welded to The Upper Reactor Vessel Closure Heads of Pressurized Water Reactors program is credited for license renewal,--AND A1.5 B2.1.5 Nickel-Alloy Penetration Nozzles Welded to The Upper Reactor Vessel Closure Heads of Pressurized Water Reactors PriorF to_ 6DoGe~ber

31. 2008. the PVNGS Alloy 600 Manaaoont I Droornm i-'ii 1il bo re~vised to inORGEornFte theo aDnhlC3DlO exa3inaticn rIequiremenRt of ASME Code Case N 729 1 (Reactor Vessel Head ln~octons 8uiotnt tho; rpoitio~n5 smanfifled-in.1 rl r, C D r, ri r, r, (RCTSAI 3246894) (CompleteQ 8 (LR^A Amendment

3) A1.6 Ongoing Existing Flow-Accelerated Corrosion program is credited for license B2.1.6 renewal AND Flow-Accelerated PFrior to the Of extended operation, the program will be enhanced Corrosion to claif,' the guidance for SUsceptible small bore (Ccmnpleted4.(RCTSAI 3246895)9 Existing Bolting Integrity program is credited for license renewal. A1.7 Ongoing (RCTSAI 3246896) B2.1.7 Bolting Integrity 10 Existing Steam Generator Tube Integrity program is credited for license A1.8 Ongoing renewal. B2.1.8 (RCTSAI 3246897) Steam Generator Tube Integrity Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-43 Appendix A Updated Final Safety Analysis Report Supplement Tnhhlg 6,d-- I it-,OnCN PQZA/ (>ri (LRA Amcndmen"3 Existing Open-Cycle Cooling Water System program is credited for license renewal, AND Prior to the period of extended operation, the program will be enhanced to-A1.9 B2.1.9 Open-Cycle Cooling Water System FPrior to the period o0 extended operation 1 NflF!G tI'hinu ntHE GOnhtAGI 9.nnric Brhrr (CgG ntFd I I RInd 1..........

• -clarify guidance in the conduct of piping inspections using NDE techniques and related acceptance criteria.(RCTSAI 3246898)12 Existing Closed-Cycle Cooling Water System program is credited for Al.10 Prior to the period of license renewal, AND B2.1.10 extended operation 1.Prior to the period of extended operation, procedures will be enhanced to Closed-Cycle Cooling incorporate the guidance of EPRI TR-1 07396 with respect to water Water System chemistry control for frequency of sampling and analysis, normal operating limits, action level concentrations, and times for implementing corrective actions upon attainment of action levels.(RCTSAI 3246899)13 Existing Inspection Of Overhead Heavy Load And Light Load (Related To A1.11 Prior to the period of Refueling)

Handling Systems program is credited for license renewal, B2.1.11 extended operation 1.AND Inspection Of Prior to the period of extended operation, procedures will be enhanced to Overhead Heavy Load inspect for loss of material due to corrosion or rail wear. And Light Load (RCTSAI 3246900) (Related To Refueling)

Handling Systems Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-44 Appendix A Updated Final Safety Analysis Report Supplement (LRA Amendment 12)Existing Fire Protection program is credited for license renewal, AND-Prior to the period of extended operation procedures will be enhanced to perform the testino of the Electro-Thermal Links (ETLs) and functional A1.12 B2.1.12 Fire Protection Prior to the period ot extended operation 1.testing of the halon and CO dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the period of extended operation., the following enhancGments Will be 9rplemReRted-.

P ,oc.d....ro will be enhanced to state trending r..uir...nt6 for the diersel driven fire PUMP. (Cempletcd)

• Procedures will be enhanced to include visual inspection of the fuo-l su1pply line to detect degradation. (Completed)

DProcedures will be eRhanRed to nspcc for mc-c--;-haial damageI , corrosion and !Ess of material of the halon discharge pipe header (Completed) and the G02 system dirscharge nozzles.,eProcedures will be enhanced to state the qualification requirements for inspecting penetr.ation sea-ls "ir rated doors, fire barier walls,1 ceilings and floors.(RCTSAI 3246901)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-45 Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments No. Schedule~15 (LRA Amc..dment

9) A1.13 Prior to the period of Existing Fire Water System program is credited for license renewal, AND B2.1.13 extended operation'.

Prior to the period of extended operation, the following enhancements will Fire Water System be implemented:

• Specific procedures will be enhanced to include review and approval requirements under the Nuclear Administrative Technical Manual (NATM).* Procedures will be enhanced to be consistent with the current code of record or NFPA 25 2002 Edition.* Procedures will be enhanced to field service test a representative sample or replace sprinklers prior to 50 years in service and test thereafter every 10 years to ensure that signs of degradation are detected in a timely manner.* Procedures will be enhanced to be consistent with NFPA 25 Section 7.3.2.1, 7.3.2.2, 7.3.2.3, and 7.3.2.4." Procoduros will bo enhanced to state t8reding roquiromont6s.

&P-ro.edures will be enhanced so that the PVNGS Quality Assurance programs will apply to Fire Pro~tection)

SSC~s that are within the sco~pe of license8 renewal that are also pa~t of the boundar,'

Of the VWF (Water ReclamqationR Facility).(Cmpleted)(RCTSAI 3246902)Palo Verde Nuclear Generating Station Amendment 20 Page A-46 License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement (LRA A mondmcnt 3)Existing Fuel Oil Chemistry program is credited for license renewal, AND Prior to the period of extended operation:

• Procedures will be enhanced to extend the scope of the program to include the SBOG fuel oil storage tank and SBOG skid fuel tanks.* Procedures will be enhanced to include ten-year periodic draining, cleaning, and inspections on the diesel-driven fire pump day tanks, the SBOG fuel oil storage tank, and SBOG skid fuel tanks." Ultrasonic testing (UT) or pulsed eddy current (PEC) thickness examination will be conducted to detect corrosion-related wall thinning if degradation is found during the visual inspections and once on the tank bottoms for the EDG fuel oil storage tanks, EDG fuel oil day tanks, diesel-driven fire pump day tanks, SBOG fuel oil storage tank, and SBOG skid fuel tanks. The onetime UT or PEC examination on the tank bottoms will be performed before the period of extended operation.(RCTSAI 3246903)A1.14 B2.1.14 Fuel Oil Chemistry Prior to the period ot extended operation 1.Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-47 Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renew Item No.17 Existing Reactor Vessel Surveillance program is credited for license renewal, AND Prior to the period of extended operation:

• The schedule will be revised to withdraw the next capsule at the equivalent clad-base metal exposure of approximately 54 EFPY expected for the 60-year period of operation, and to withdraw remaining standby capsules at equivalent clad-base metal exposures not exceeding the 72 EFPY expected for a possible 80-year second period of extended operation.

This withdrawal schedule is in accordance with NUREG-1801,Section XI.M31, item 6, and with the ASTM E 185-82 criterion which states that capsules may be removed when the capsule neutron fluence is between one and two times the limiting fluence calculated for the vessel at the end of expected life.This schedule change must be approved by the NRC, as required by 10 CFR 50 Appendix H." If left in the reactor beyond the presently-scheduled withdrawal, the next scheduled surveillance capsule in each unit will reach a clad-base metal 54 EFPY equivalent at about 40 actual operating EFPY (40, 39, and 42 actual EFPY in Units 1, 2, and 3, respectively).

• Procedures will be enhanced to identify the withdrawal of the remaining standby capsules at 72 EFPY, at about 50 to 54 actual operating EFPY, near the end of the extended licensed operating period. The need to monitor vessel fluence following removal of the remaining standby capsules, and ex-vessel or in-vessel methods, will be addressed prior to removing the remaining capsules.(RCTSAI 3246904)A1.1b B2.1 15 Reactor Vessel Surveillance Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-48 Appendix A Updated Final Safety Analysis Report Supplement The One-Time Inspection program conducts one-time inspections of plant system piping and components to verify the effectiveness of the Water Chemistry program (Al.2), Fuel Oil Chemistry program (A1.14), and Lubricating Oil Analysis program (Al.23). The aging effects to be evaluated by the One-Time Inspection program are loss of material, cracking, and reduction of heat transfer.(RCTSAIs 3246906 [Ull; 3247258 [U21; 3247259 [U31)Al.1b B2.1.16 One-Time Inspection within trie ten year period prior to the period of extended operation'.

Prior to the period oe extendGd eperatieRns 19 (LRA Amendment

12) A1.17 Within the 4--tenayear The Selective Leaching of Materials program is a new program that will B2.1.17 period prior to the be implemented prior to the period of extended operation.

Industry and Selective Leaching Of period of extended plant-specific operating experience will be evaluated in the development Materials operation'.

and implementation of this program.(RCTSAIs 3246908 [U1]; 3247260 [U2]; 3247261 [U3])20 (LRA Amendment

17) A1.18 Perform the buried The Buried Piping and Tanks Inspection program is a new program that B2.1.18 piping and tanks will be implemented prior to the period of extended operation.

Buried Piping And inspections Wwithin Tanks Inspection the ten year period Within the ten year period prior to entering the period of extended prior to the period of operation an opportunistic or planned inspection of buried tanks at the extended operation'.

Palo Verde site will be performed.

Within the ten year period prior to entcring the pcried of extended apcratiGn the buried piping inspectionG AND noted below will be performed.

The buried piping inspectionsr noted below will be performed within the firSt ten yearS Of the period oGf Within the fir-st ten extended.

year-sPerform the buried piping The visual inspections noted below of piping in a soil environment within inspections during the scope of license renewal will be conducted within the ten-year period each ten year period prior to entering the period of extended operation, and aga.R ,i +-th- after entering the fwet teR yeaF&during each ten year period after entering the period of period of extended extended operation.

Each inspection will: operation.

0 select accessible locations where degradation is expected to AND Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-49 Appendix A Updated Final Safety Analysis Report Supplement be high;o excavate and visually inspect the circumference of the pipe;and* examine at least ten feet of pipe.Implement the additional enhancements to the buried piping and tanks inspection program prior to the period of operation'.

a. Metallic Piping not Cathodically-Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems: o Chemical and Volume Control (CH), o Condensate Transfer and Storage (CT), and o Fire Protection (FP).b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit.c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.Prior to the perod of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried pipinq at least 90% of the time (e.g., monthly verification thatthe power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE) cathodic protection system surveys are performed at least annually.(RCTSAIs 3246909 [U1]; 3247263 [U2]; 3247264 [U3])I Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-50 Appendix A Updated Final Safety Analysis Report Supplement (LRA Amcndment 3)The One-Time Inspection of ASME Code Class 1 Small-Bore Piping program is a new program that will be implemented prior to the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.(RCTSAIs 3246910 WUll: 3247265 [U21: 3247266 [U31)A1.19 B2.1.19 One-Time Inspection of ASME Code Class 1 Small-Bore Piping Hrior to tfe period ot extended operation 1.22 The External Surfaces Monitoring Program is a new program that will be A1.20 Prior to the period of implemented prior to the period of extended operation.

Industry and B2.1.20 extended operation 1.plant-specific operating experience will be evaluated in the development External Surfaces and implementation of this program. Monitoring Program (RCTSAIs 3246911 [U11]; 3247272 [U2]; 3247273 [U3]) I Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-51 Appendix A Updated Final Safety Analysis Report Supplement 23 (LRA Amcndm.nt 15)APS will: A. Reactor Coolant System Nickel Alloy Pressure Boundary Components Implement applicable (1) NRC Orders, Bulletins and Generic Letters associated with nickel alloys and (2) staff-accepted industry guidelines, (3) participate in the industry initiatives, such as owners group programs and the EPRI Materials Reliability Program, for managing aging effects. associated with nickel alloys, (4) upon completion of these programs, but not iess than 24 months before entering the period of extended operation, APS will submit an inspection plan for reactor coolant system nickel alloy pressure boundary components to the NRC for review and approval, and B. Reactor Vessel Internals (1) Participate in the industry programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, APS will submit an inspection plan for reactor internals to the NRC for review and approval.C. Pressurizer Spray Heads Comply with applicable NRC Orders and implement applicable (1)Bulletins and Generic Letters, and (2) staff-accepted industry guidelines.(RCTSAIs 3246912 [Ul]; 3247274 [U2]; 3247276 [U3])A1.21 B2.1.21 Reactor Coolant System Supplement Not less than 24 months prior to the period of extended operation'.

3.1.2.2.16.2 Pressurizer spray head cracking 24 The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting A1.22 Prior to the period of Components program is a new program that will be implemented prior to B2.1.22 extended operation 1.the period of extended operation.

Industry and plant-specific operating Inspection Of Internal experience will be evaluated in the development and implementation of Surfaces In this program. Miscellaneous Piping (RCTSAIs 3246914 [Ul]; 3247277 [U2]; 3247278 [U3]) And Ducting Components Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-52 Appendix A Updated Final Safety Analysis Report Supplement Lxisting LuDricating Uil (RCTSAI 3246915)B2.1.23 Lubricating Oil Analysis 26 The Electrical Cables and Connections Not Subject to 10 CFR 50.49 A1.24 Prior to the period of Environmental Qualification Requirements program is a new program that B2.1.24 extended operation'.

will be implemented prior to the period of extended operation.

Industry Electrical Cables And and plant-specific operating experience will be evaluated in the Connections Not development and implementation of this program. Subject to 10 CFR (RCTSAI 3246917) 50.49 Environmental Qualification Requirements 27 (LRA Amendment

9) A1.25 Prior to the period of Existing Electrical Cables And Connections Not Subject To 10 CFR 50.49 B2.1.25 extended operation 1.Environmental Qualification Requirements Used In Instrumentation Electrical Cables And Circuits program is credited for license renewal , AND Connections Not Prior to the period of extended operation:

Subject To 10 CFR" Procedures will be enhanced to identify license renewal scope, 50.49 Environmental require cable testing of ex-core neutron monitoring cables, require an Qualification evaluation of the calibration results for non-EQ area radiation Requirements Used In monitors, and require acceptance criteria for cable testing be Instrumentation established based on the type of cable and type of test performed.

Circuits_ Procedures will be eRhaRced to require that an action requeSt beH&;A.A~on hon the loop cannot 138 calibratod to moot accoptance criteria. (Completed)(RCTSAI 3246919)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-53 Appendix A Updated Final Safety Analysis Report Supplement mmitments Commitment The Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 EQ Requirements program is a new program that will be implemented prior to the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.(RCTSAI 3246920)B2.1.26 Inaccessible Medium Voltage Cables Not Subject To 10 CFR 50.49 Environmental nrior to tne perioa OT extended operation 1.Qualification Requirements 29 Existing ASME Section Xl, Subsection IWE program is credited for A1.27 Ongoing license renewal. B2.1.27 (RCTSAI 3246921) ASME Section Xl, Subsection IWE 30 Existing ASME Section Xl, Subsection IWL program is credited for A1.28 Ongoing license renewal. B2.1.28 (RCTSAI 3246922) ASME Section Xl, Subsection IWL 31 Existing ASME Section XI, Subsection IWF program is credited for A1.29 Ongoing license renewal. B2.1.29 (RCTSAI 3246923) ASME Section Xl, Subsection IWF 32 Existing 10 CFR 50, Appendix J program is credited for license renewal. A1.30 Ongoing (RCTSAI 3246924) B2.1.30 10 CFR 50, Appendix J 33 Existing Masonry Wall Program is credited for license renewal, AND A1.31 Prior to the period of Prior to the period of extended operation, procedures will be enhanced to B2.1.31 extended operation 1.specify AC! 349.3R-96 as the reference for qualification of personnel to Masonry Wall Program inspect structures under the Masonry Wall Program, which is part of the Structures Monitoring Program.(RCTSAI 3246926)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-54 Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Ite CommritmeintY tRA Section Sheduentto 34 (LRA Amendment

15) A1.32 Prior to the period of Existing Structures Monitoring Program is credited for license renewal, B2.1.32 extended operation'.

AND Structures Monitoring Prior to the period of extended operation:

Program" The Structures Monitoring Program will be enhanced to specify ACI 349.3R-96 as the reference for qualification of personnel to inspect structures under the Structures Monitoring Program." For structures within the scope of license renewal, the Structures Monitoring Program will be enhanced to establish the frequency of inspection for each unit at a 5 year interval, with the exception of exterior surfaces of the following nonsafety-related structures, below-grade structures, and structures within a controlled interior environment, which will be inspected at an interval of 10 years:* Fire Pump House (Yard Structures)

• Radwaste Building* Station Blackout Generator Structures

• Turbine Building* Non-Safety Related Tank Foundations and Shells* Non-Safety Related Transformer Foundations and Electrical Structures" The Structures Monitoring Program will be enhanced to quantify the acceptance criteria and critical parameters for monitoring degradation, and to provide guidance for identifying unacceptable conditions requiring further technical evaluation or corrective action.Procedures will also be enhanced to incorporate applicable industry codes, standards and guidelines for acceptance criteria.(RCTSAI 3246927)Palo Verde Nuclear Generating Station Amendment 20 Page A-55 License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement Existing I-u 1.12f, Inspection Ut water-(Uontrol Structures Associatea With Nuclear Power Plants program is credited for license renewal, AND Prior to the period of extended operation, procedures will be enhanced to specify that the essential spray ponds inspections include concrete below the water level.(RCTSAI 3246928)A1.66 B2.1.33 RG 1.127, Inspection Of Water-Control Structures Associated With Nuclear Power Plants t'rior to me perioa O0 extended operation'.

____ +/- 36 (LRDA Supplement 1)Existing Nickel Alloy Aging Management Program is credited fur license renewal, AND Prir to the period of extenRded opeFrain, the PVNGS Alloy 600 Management Program Plan will be en~hanccd tc add Alloy 600 steam generator comTponents, including tube shoot cladding -nd portions, of the priar, nzzle cladding (RrTSAl 3246929) (Completed), ANID In addition, prier to December,31, 2008, tePVNGS Alloy 600 Management Pro~gram Plan will be revised to incrEGporate the applica~blle A1.34 B2.1.34 Nickel Alloy Aging Management Program Ongoing.I Head Inspections;), subject to the conditions spocifed in 10 C-FR F5 throuoh(6) and ASM Cod Cas N-l -Ah 72+;In.4 P1 P'I~I~ rA rrI~XIf\I::\II~XI.V~

4L....v\VVI IV .....\V/.(RCTSAI 3260208) r^ompletedl,j.-37 The Electrical Cable Connections Not Subject to 10 CFR 50.49 A1.35 Prior to the period of Environmental Qualification Requirements program is a new program that B2.1.35 extended operation'.

will be implemented prior to the period of extended operation.

Industry Electrical Cable and plant-specific operating experience will be evaluated in the Connections Not development and implementation of this program. Subject To 10 CFR (RCTSAIs 3246930 [U1]; 3247228 [U2]; 3247231 [U3]) 50.49 environmental qualification requirements Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-56 Appendix A Updated Final Safety Analysis Report Supplement The Metal Enclosed Bus program is a new program and will be completed before the period of extended operation and once every 10 years thereafter.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.(RCTSAIs 3246932 [Ul]; 3247220 [U2]; 3247221 [U3])A1.36 B2.1.36 Metal Enclosed Bus Prior to the period ot extended operation and once every ten4-0 years thereafter.

I 39 (LRA

)No later than two years prior to the period of extended operation, the following enhancements will be implemented

• Cumulative usage factor tracking will be implemented for NUREG/CR-6260 locations not monitored by cycle counting (the reactor vessel shell and lower head (juncture) location will be monitored by cycle counting).

For PVNGS locations identified in NUREG/CR-6260 and monitored by CUF, fatigue usage factor action limits will be required for including effects of the reactor coolant environment." The Metal Fatigue of Reactor Coolant Pressure Boundary program will be enhanced to include a computerized program to track and manage both cycle counting and fatigue usage factor.FatiguePro will be used for cycle counting and cycle-based fatigue (CBF) monitoring methods. FatiguePro is an EPRI licensed product.* The enhanced Metal Fatigue of Reactor Coolant Pressure Boundary program will monitor plant transients as required by PVNGS Technical Specification 5.5.5. Cumulative usage factors (CUFs) will be calculated for a subset of ASME III Class 1 reactor coolant pressure boundary vessel and piping locations, and component locations with Class 1 analyses.

The following methods will be used: 1) The Metal Fatigue of Reactor Coolant Pressure Boundary program will be enhanced to use cycle based fatigue (CBF)and stress based fatigue (SBF) CUF calculations to monitor fatique. FatiguePro will be used for cycle countinq and cycle-4.3.1 Fatigue Aging Management Program A2.1 B3.1 Metal Fatigue of Reactor Coolant Pressure Boundary No later than two years prior to the period of extended operation'.

Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-57 Appendix A Updated Final Safety Analysis Report Supplement 44-1 License Renewal Commitments ComtetLRA Section ~ Implemientation based fatigue (CBF) monitoring methods. FatiguePro is an EPRI licensed product.2) The SBF method will use a fatigue monitoring software program that incorporates a three-dimensional, six-component stress tensor method meeting ASME III NB-3200 requirements., The enhanced Metal Fatigue of Reactor Coolant Pressure Boundary program will provide action limits on cycles and on CUF that will initiate corrective actions before the licensing basis limits on fatigue effects at any location are exceeded.o In order to ensure sufficient cycle count margin to accommodate occurrence of a low-probability transient, corrective actions must be taken before the remaining number of allowable occurrences for any specified transient becomes less than 1.o CUF action limits will be established to require corrective action when the calculated CUF (from cycle-based or stress-based monitoring) for any monitored location is projected to reach 1.0 within the next 2 or 3 operating cycles. In order to ensure sufficient margin to accommodate occurrence of a low-probability transient, corrective actions will be taken while there is still sufficient margin to accommodate at least one occurrence of the worst-case design transient event (i.e., with the highest fatigue usage per event cycle).(RCTSAI 3246934)40 Amendment

0) A2.2 Prior to the period of Existing Environmental Qualification program is credited for license B3.2 extended operation'.

renewal, AND Environmental maintaining qualification through the extended license renewal period Qualification (EQ) Of requires that existing EQ evaluations (EEQDFs) be re-evaluated.

Electrical Components (RCTSAI 3246935)Palo Verde Nuclear Generating Station Amendment 20 Page A-58 License Renewal Application Appendix A Updated Final Safety Analysis Report Supplement Existing Concrete Containment Tendon Prestress program is credited for license renewal, AND o The program will be enhanced to continue to compare regression-analysis trend lines of the individual lift-off values of tendons surveyed to date, in each of the vertical and hoop tendon groups, with the MRV and PLL for each tendon group, to the end of the licensed operating period, and to take appropriate corrective actions if future va!ues indicated by the regression analysis trend line drop below the PLL or MRV. The regression analyses will be updated for tendons of the affected unit and for a combined data set of ali three units following each inspection of an individual unit.Prior to the period of extended operation, procedures will be enhanced to require an update of the regression analysis for each tendon group of each unit, and of the joint regression of data from all three units, after every tendon surveillance.

'The documents-will invoke and describe regression analysis methods used to construct the lift-off trend lines, including the use of individual tendon data in accordance with Information Notice (IN) 99-10, "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments." The Tendon Integrity test procedure will be revised to extend the list of surveillance tendons to include random samples for the year 45 and 55 surveillances.(RCTSAI 3246937)B3.3 Concrete Containment Tendon Prestress i-rior to tne penoa OT extended operation'.

4.5 Concrete Containment Tendon Prestress 42 APS will confirm the RCS Pressure-Temperature limits basis for 54 EFPY A3.1.3 Prior to operation prior to operation beyond 32 EFPY and will update documents in Pressure-Temperature beyond 32 EFPY 1.accordance with the provisions of 10 CFR 50.59. (RCTSAI 3246939) Limits Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-59 Appendix A Updated Final Safety Analysis Report Supplement wal Commitments Commitment I I I I L II 415 i M^ ý^ ý-r ^T Tný nd ýn %IQM+ M^ UuIrn nil rQCIUCOO 9 the remoeval of indications will be replaced when the vessel headi replaced, and its fatigue analysis will be revised. The repair and the revised fatigue analysis will demonsRtrate an adequate fatigue lifle,-A n +n +k nnA -F+knn,.,nnn~rnn.+n

A -F + A J.i~16.Reactor Pressure Vessel, Nozzles&, Head, and Studs Prior to the period of exteRded peratin 4" with 10 CFR 54.21 ()(4)(ii).

This is a commitment for liense renewal.COMoleted (RCTSAI 3246941)44 (LRA Suppla""nt 1)During the review process APS identified a number of ASME Inn Class valves greater than fourF incheI n.. omina inle-t that Might requir a f.atiuLe 4.3.2.6 A3.2.1.ASME Section I Class 1 Valves Completed.

analysis, 9uK fOr nIcn Mne analysis was net i1 ediateiy rotrevaaie.

Effort are ongoing to con.fiFrm the- neeAd for- anRd if n9eesary to obtain those analyses.

APS will recover and evaluate the fatigue analysis for...............

..... g A ...... ....... .... -ILL va ve gre te ..... .. -wu .. ... .. .... .. ..inlet, for which a fatigue analysisor , also othernise required, befo~re tilhe e~d Ofith8GFento re'ied foerathe neriod. of ~ exEnde thesei aRalyses Oil be validated 9F Fevised feF the peFied of exteRded epeFatiOR:_ I L- ------,4 L,,,4.L--

KA-4--I -f* I C'~~~tI Vnlen+ Hmeim n nJ~n m-tj Wy tE Ev EvitnCIE ffC3tMqUvv toi "CKA".Completed (RCTSAI 3253459)Supplement 1 April 10, 2009 Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-60 Appendix A Updated Final Safety Analysis Report Supplement 2005, PVNU~b submitted AH6 Icttcr 1 02 Ob2j ( to ther roquost ;br exemnption trom the If/a.' removal and sucOGGIVe requiroments of ASMEI Xl (1992) -sciions IWA 3300 and IWVB 2420, for the alternative half nozzie method used for the 10 PVNGS Unit 2 small bore, hot leg nozzlos to be repaired during the Spring 2005 refueling outage. WOGAP 1597-3 P cacIulated co)rro96ion rFates of 1.53 mils per year (mpy) for Alloy 600 nozzles. In FcSPOnie to the conditionS o f the final safety evaluation for the Wes3tinghouse topical repGot, APS calculated that!;ir ;+in-- --;-ed~r r-+^ ^f 1 ')77 n-, , f-r I [ý+Ird n ... J n.,1, -+ v-----,4 k-Fatigue CrFack Growt~h and F~aGtU~e Mechanics Stability ARaeyses ef-Hf NozeRepai~rs to Alloy 600 Material in ReactorF Coolant Hot Legs; Absence of a TL/, for Corrosion Analyses a, llo le dimeter until 2,058, 60 years after the repair and 10 afte the end of the period Of eXtended operation.

This calculation is therefore rot a TiAA, aRd rs valid for the of extended ope;atin..

However, the relief request submittal, APS made an ongoing co)mmitment to track the time at seld sh'-tdow;-n conditiens:

APS co)mmits to continu1e to track the time at cold shutdown conditfios againSt the assumptions made t,.-.,.-.,., analysis to assure that tha allowable bore diameter !s not exceeded over the life of the plant. If the analysis assumpt-fions are eXceeded, APS shall provide a revised analysis to the NRC and provide a discussion on whether voluImnetFic f the area This co)mm:Aitm.ent was mflade because the corrosion rate at cold shutdown conRditions is significantly higher than at operating conditions.

This request was, authorized-d by the NRC, consis6tent With the AIS- rcommmitment and is valid for the second, third, aRd fourth 10 year inspection inteFVals.

Therefore, an extension of this authorization will be required forn tinued relief fte the ARME GE)de SeGt*OR6 See Item No. 46 (RCTSAI 3246943)I See Item No. 46 (RCTSAI 32469434 L _________________________

+/-Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-61 Appendix A Updated Final Safety Analysis Report Supplement tP 15973 P analysis Of corrosion-

R the hot leg pipe wall duet e.tended by APSf-or a ...f the poriod f oxtendo eperatiG,-and-!

th EI net a TLo owver the reief from the ASME Secti-. X " rqu reets is an APS commitment to continuetoack the tim at coldhtd n ticns against the assumptions made i te he-cer-osion c 4w"a'su ... hat the al+owable boro diametc-r--s-g-a~-exeedede-3veF the life of thes plant.Thspormia coRditiGRonf Revision ito Relief Rqet321 -f P9 LtteF 102 05321, granted by the NRC, and is applicabc.-

to all the , units for t+e -e o,'third, aRnd fourth year An extension of t4ls-ISI Relief Request 31, Revision 1 authorization will be requested for the period of extended operation, supported by a continuation of the cold shutdown time monitoring program.(RCTSAI 3246945)* .I- .ý-Fatigue Crack Growth-and Fracture Mechanics Stability Analyses of Half-Nozzle Repairs to Alloy 600 Material in Reactor Coolant Hot Legs; Absence of a TLAA for Supporting Corrosion Analyses Prior to the period of extended operation'.

47 Once the ground surface is made less permeable and ambient monitoring Environmental Report 12/31/10 is sufficient to characterize subsurface water quality, a [tritiated water] 2.3 o remediation plan will be implemented.(RCTSAI 3246946)48 New Evaporation Pond No. 3 is currently under construction and is being Environmental Report 12/31/15 built using a Best Available Demonstrated Control Technology (BADCT), 3.1.2 a geosynthetic clay liner, with two overlaying HDPE liners, including a leachate collection and recovery system, plus soil cement side armoring, including a leak detection system. Following that, the existing liner in Evaporation Pond No. 2 will be replaced with the same BADCT liner system. This liner is approaching the end of its useful life. Following that, the existing liner in Evaporation Pond Number 1 will be replaced with the same BADCT liner system.(RCTSAI: 3246947)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-62 Appendix A Updated Final Safety Analysis Report Supplement (LRA Amendment 2)APS commits to implement SAMAs 6, 17 and 23 prior to the period of extended operation.(RCTSAI 3246952)Environmental D.8 Prior to the period ot extended operation 1.50 (11=4A Amrendment

3) A1.37 Prior to the period of The Fuse Holder program is a new program that will be implemented B2.1.37 extended operation prior to the period of extended operation and once every 10 years Fuse Holder and once every 10 thereafter.

Industry and plant-specific operating experience will be years thereafter.

evaluated in the development and implementation of this program (RCTSAI 3409443)51 (LRA Amendment

3) B2.1.34 12/31/10 The original Unit ! -ad Unit 3 reactor pressure vessel (RPV) heads are Nickel Alloy Aging is_planned to be replaced during the fall refueling outages in 2010. All Management Program components penetrating the new heads and welds including the head vent will be replaced with Alloy 690. The Unit 2 RPV head was replaced during 2R15 outage in fall 2009, and the Unit 1 RPV head was replaced during 1 R15 in spring 2010.(RCTSAI 3410460)52 (LRA Amendment

7) Follow-up Response to Prior to the period of APS will consider SAMA 8 for potential implementation.

SAMA RAI (letter no. extended operation'.(RCTSAI 3420542) 102-06121, dated January 13, 2010)53 (ILRA Amendment

15) Response to RAI 4.5 1 Completed Theo hanges to LRA Tablo 1.5 1 6hown in the rosponso to RAI 4.5 1, and in APS Iottor no.changes to LRA Figurcs 1.5 1, 2, 5, and 6 to reflect the results of the 102 06160, dated Unit 1 25 year to ndon surpeillance data regression analysis, will bo 44/10.submi~ttodr to the NRC in an LRA amendment by May 28, 2010 Completed Complete~d(RCTSAI 3429933) _________Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-63 Appendix A Updated Final Safety Analysis Report Supplement T.mhI, 8,d--l I it-'One P93nO1wj:) (ncMMitM,~nt(L, A-mendment 11)By August 30, 2010, APS will ensure that that the abandoned containment spray chemical addition tanks and associated piping components in PVNGS Units 1, 2, and 3 are drained to preclude any spatial interactions with safety related components.(RCTSAI 3443855)Response to RAI 2.1-03, Issue (2), in APS letter no. 102-06162, dated 4/2/10 55 (LRA Amendment 4.3.1 8/25/10 The transient in UFSAR Table 3.9-1 Sheet No. 9 Item No. L.E.1 .b, and Fatigue Aging Sheet No. 18, Item No. lilI.A.1.f, "Standby to SI hot leg injection check Management Program valve stroke test to standby (using the HPSI pump)," wilH be added to the (Table 4.3-2, Row No.cycle counting surveillance procedure 73ST-9RC02 by August 25, 2010. 25)(RCTSAI 3469024)56 (LRA Amendment

17) Follow-up 12/31/2015 The spray pond wall rework/repair methods.are currently being Response to RAI determined, and the rework/repair is planned to begin in 2011. As Unit 1 B2.1.33-2 (letter no.spray ponds have the most degradation, work is planned to start there 102-06205, dated followed by Units 2 and 3. It is expected that the work will be completed June 21, 2010)in all three units in 2015.(RCTSAI 3484623)57 (LRA Amendment

18) Response to RAI RAI No later than two No later than two years prior to the period of extended operation, APS will 4.3-6 (letter no. years prior to the confirm the conservatism of the Fen value of 1.49 using the methods 102-06210, dated period of extended specified in NUREG/CR-6909, and will use the Fen calculated using the June 29, 2010) operation 1.NUREG/CR-6909 methods if it is more conservative than the 1.49 value.(RCTSAI 3488220)58 (LRA Amendment

18) Response to RAI RAI No later than two No later than two years prior to the period of extended operation, APS will 4.3-6 (letter no. years prior to the perform a reanalysis of the pressurizer heater penetrations to consider 102-06210, dated period of extended EAF effects using the formulas and methodology given in NUREG/CR-June 29, 2010) operation 1.6909.(RCTSAI 3488223)Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-64 Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments (1) "Prior to period of extended operation," "prior to operation beyond 32 EFPY," and "prior to the end of the current licensed operating period," is prior to the following PVNGS Operating License expiration dates: Unit 1: June 1, 2025; Unit 2: April 24, 2026; Unit 3: November 25, 2027.Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page A-65 Appendix B AGING MANAGEMENT PROGRAMS B1.3 QUALITY ASSURANCE PROGRAM AND ADMINISTRATIVE CONTROLS The PVNGS Quality Assurance Program implements the requirements of 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants," and will-be is consistent with the summary provided in Appendix A.2 of NUREG-1800 and the Appendix, "Quality Assurance for Aging Management Programs" of NUREG-1801. The PVNGS Quality Assurance Program includes the elements of corrective action, confirmation process, and administrative controls.

The PVNGS Quality Assurance Program is applicable to all safety-related and, after enhancement, will also be applicable to all nonsafety-related systems, structures, and components (SSCs) that are subject to aging management activities.

Each of these three elements is applicable as follows: Corrective Action PVNGS applies its corrective action process to safety-related and, after enhancement, nonsafety-related systems, structures, and components that are subject to aging management.

Corrective action process procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants. Conditions adverse to quality (such as failures, malfunctions, deviations, defective material and equipment, and nonconformances) are promptly identified and corrected.

Significant conditions adverse to quality (such as failures, malfunctions, deviations, defective material and equipment, and nonconformances) are promptly identified and corrected.

In the case of significant conditions adverse to quality, measures are implemented to ensure that the cause is determined and that corrective action is taken to preclude repetition.

In addition, the root cause of the significant condition adverse to quality and the corrective actions implemented are documented and reported to appropriate levels of management.

Confirmation Process The PVNGS Quality Assurance Program requires that measures be taken to preclude repetition of significant conditions adverse to quality. These measures include actions to verify effective implementation of corrective actions.Plant procedures include provisions for timely evaluation of adverse conditions and implementation of any corrective actions required, including root cause determinations and prevention of recurrence where appropriate (e.g., significant conditions adverse to quality).These procedures provide for tracking, coordinating, monitoring, reviewing, verifying, validating, and approving corrective actions, and to ensure corrective actions have been effectively implemented.

The corrective action process is also monitored for potentially adverse trends. Identification of a potentially adverse trend due to recurring or repetitive unacceptable conditions will result in the initiation of a corrective action document.Follow-up inspections required by the confirmation process are documented in accordance with the corrective action process. The corrective action process constitutes the confirmation process for aging management programs and activities.

The same 10 CFR 50 Palo Verde Nuclear Generating Station Amendment 20 Page B-2 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS Appendix B corrective actions and confirmation process applies to nonconforming systems, structures, and components subject to aging management review.Administrative Controls PVNGS administrative controls require formal procedures and other forms of written instruction for the activities performed under the programs credited for managing aging.These PVNGS procedures contain objectives, program scope, responsibilities, methods for implementation, and acceptance criteria.Enhancements will be erhanr-ed manaagcmcnt 1'Ai fthin thc Scope to- include those nonsafoty of the PVNGS Quality Assu-r +: A A FerSS-s r,,equiring aging nce Ptrogtr to address the; wiStrativo controls.

None ele A -.6 A-1 -W. I ---At "-. 0 ý- -W CXtJ Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page B-3 Appendix B , AGiNG MANAGEMENT PROGRAMS B2.1.12 Fire Protection Program Description The Fire Protection program manages loss of material for fire rated doors, fire dampers, diesel-driven fire pumps, and the C02 and halon fire suppression systems, cracking, spalling, and loss of material for fire barrier walls, ceilings, and floors, and hardness and shrinkage due to weathering of fire barrier penetration seals. Periodic visual inspections of fire barrier penetration seals, fire dampers, fire barrier walls, ceilings and floors, and periodic visual inspections and functional tests of fire-rated floors are performed to ensure that they can perform their intended function.The Fire Protection program manages aging by a visual inspection on ten percent of each type of penetration seal at least once every 18 months. This sample set method ensures that each penetration seal is inspected at least once every 15 years.The Fire Protection program manages aging by a visual inspection every 18 months of the fire barrier walls, ceilings, and floors, including coating and wraps of Thermo-lag enclosures, examining for any signs of aging such as cracking, spalling, and loss of material.The Fire Protection prograrn manages aging by drop testing on ten percent of all accessible fire dampers on an 18 month basis.The Fire Protection program manages aging by performing visual inspections every 18 months on fire-rated doors to verify the integrity of door surfaces and for clearances to detect aging of the fire doors prior to the loss of intended function.The diesel-driven fire pumps are under observation during performance tests such as flow tests, start/run tests for detecting any aging of the fuel supply line. The fuel oil supply line is also managed by the Fuel Oil Chemistry program (B2.1.14) and External Surface Monitoring Program (B2.1.20).

A visual inspection and function test of the halon and C02 fire suppression systems is performed every 18 months (with the exception of destructive testing of the Electro-Thermal Links (ETLs) and functional testing of the dampers which are performed every 54 months).NUREG-1801 Consistency The Fire Protection program is an existing program that, following enhancement, will be consistent with NUREG-1801,Section XI.M26, "Fire Protection," with an exception.

Exceptions to NUREG-1801 Program Elements Affected Parameters Monitored or Inspected

-Element 3 and Detection of Aging Effects -Element 4 NUREG-1801 recommends a visual inspection and function test of the halon and C02 systems every six months. The PVNGS procedures for visual inspections and function testing of the halon and C02 fire suppression systems are performed every 18 months Palo Verde Nuclear Generating Station Amendment 20 Page B-45 License Renewal Application

• "Appendix B AGING MANAGEMENT PROGRAMS (excluding destructive testing of the Electro-Thermal Links (ETLs) and functional testing of the dampers, which are both performed every 54 months per TSR 3.11.103.5, 3.11.103.6, 3.11.106.5 and 3.11.106.6) per Technical Requirements Manual Surveillance Requirement (TSR) 3.11.106.4 and 3.11.103.4, respectively.

These functional tests will also identify any mechanical damage of the halon and CO 2 fire suppression system that prevents the system from performing its intended function.

With respect to the 54 month destructive testing of the Electro-Thermal Links (ETLs), PVNGS has performed an engineering analysis, consistent with the methodology described within EPRI Technical Report 1006756 "Fire Protection Equipment Surveillance Optimization and Maintenance Guide 2003" to extend the frequency of the test so that the confidence of functionality obtained by successful completion of the test is aligned with reliability and logistical concerns of the test. The calculation indicates that a full functional test every six years of the dampers actuated by ETLs will maintain a 95% success rate assuming the same amount of failures as have occurred in the last 10 years and adjusting for uncertainty at the 99% level. The selection of a testing interval of 54 months, comparedto the calculated value of 72 months for 95% success rate, provides an additional margin of protection.

The test frequency is considered sufficient to ensure system availability and operability based on station operating history that indicates no loss of intended function due to aging. A review of the past ten years of operating experience and corrective action documentation has shown no degradation or loss of intended function between test intervals.

Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements: Parameters Monitored or Inspected

-Element 3, and Detection of Aging Effects -Element 4, and AcGoptanco Critaria E!omont 6 Procedures will be enhanied fte inspect for mechanical damage, corros.ion-and loss of material oftrsystem dchrge .. z...ProcGedures will be enh;anced_

to- state the qualifica~tion.

requirements forinpctn penetrtionea, fire rated doors, fire barrier walls, ceilings and floors.Procedures will be enhanced to perform the testinq of the Electro-Thermal Links (ETLs) and functional testing of the halon and CO? dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the period of extended operation.

Operating Experience Plant operating experience indicates that there have been instances of Thermo-Lag degradation and cracking.

These portions of affected Thermo-Lag envelopes have been reworked according to PVNGS specification.

PVNGS has also experienced door skin cracks. These have been weld repaired according to specification.

During May of 2005, a fire protection audit was performed by members of APS and other industry representatives.

The audit team observed current conditions and installations of the C02 and halon suppression systems during walk-downs of selected fire zones. All systems were found in good condition.

Multiple walkdowns per unit were conducted to Palo Verde Nuclear Generating Station Amendment 20 Page B-46 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS examine the current condition of existing fire barriers in the Unit 1 control building, the Unit 2 turbine building, and the Unit 3 auxiliary building.

There was one adverse condition identified in the Unit 3 auxiliary building where copper piping was penetrating the floor barriers.

The audit team found no degraded conditions (e.g., cracks, gouges, holes in material, joint/seal gaps) of installed electrical raceway fire barriers.In September of 2006, it was discovered that a carbon steel pipe nipple was in need of replacement due to galvanic corrosion and was subsequently replaced.

The nipple was located between a galvanized tee and a brass valve. This event is representative of the PVNGS experience of detecting degradations and leakage in time to take corrective action prior to the loss of intended function.During the 2007 fire protection audit, a concern was raised for the need of a plan to identify fire protection equipment obsolescence issues. Design modifications have been identified to address these issues.Conclusion The continued implementation of the Fire Protection program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page B-47 A G N M Appendix B AGING MANAGEMENT PROGRAMS B2.1.18 Buried Piping and Tanks Inspection Program Description The Buried Piping and Tanks Inspection program manages loss of material on external surfaces of buried components in the following .systems:

chemical and volume control, condensate storage and transfer, diesel fuel storage and transfer, domestic water, fire protection, SBOG fuel system, service gas and essential spray ponds. Opportunistic visual inspections will monitor the condition of protective coatings and wrappings found on carbon steel, gray cast iron or ductile iron components and assess the condition of stainless steel components with no protective coatings or wraps. Any evidence of damaged wrapping or coating defects is an indicator of possible corrosion damage to the external surface of the components.

The Buried Piping and Tanks Inspection program is a new program that will be implemented prior to the period of extended operation.

Within the ten year period prior to entering the period of extended operation an opportunistic or planned inspection of buried tanks at the Palo Verde site will be performed.

Within the ten year period prior to entering th~e period of oXtended oporation tho bur~ied piping.inspectionS noted below wflill be performned.

The buried piping inspectionsG noted below will be perfor~med within the first ten years of the period of extended operation.

The visual inspections noted below of piping in a soil environment within the scope of license renewal will be conducted within the ten-year period prior to entering the period of extended operation, and again within the first ten years during each ten year period after entering the period of extended operation.

Each inspection will:* select accessible locations where degradation is expected to be high;* excavate and visually inspect the circumference of the pipe; and* examine at least ten feet of pipe.a. Metallic Piping not Cathodically-Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems: o Chemical and Volume Control (CH), o Condensate Transfer and Storage (CT), and o Fire Protection (FP).b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit.Palo Verde Nuclear Generating Station Amendment 20 Page B-60 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS c. Steel Piping with Potentially Degraded Cathodic Prote'ction At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.Prior to the period of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power.is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE)cathodic protection system surveys are performed at least annually.NUREG-1801 Consistency The Buried Piping and Tanks Inspection program is a new program that, when implemented, will be consistent with exception to NUREG-1 801,Section XI.M34, "Buried Piping and Tanks Inspection".

Exceptions to NUREG-1801 Program Elements Affected Scope of Program -Element I and Acceptance Criteria-Element 6 NUREG-1801,Section XI.M34 scope only includes buried steel piping and components.

However, PVNGS also includes stainless steel in their buried piping program that will be managed as part of this aging management program.Scope of Program -Element 1, Preventive Actions -Element 2, and Acceptance Criteria-Element 6 NUREG-1801,Section XI.M34 relies on preventive measures such as coatings and wrappings.

However, portions of buried stainless steel piping may not be coated or wrapped. Inspections of buried piping that is not wrapped will inspect for loss of material due to general, pitting, crevice, and microbiologically influenced corrosion.

Enhancements None Operating Experience The Buried Piping and Tanks Inspection program is a new program. Degradation of buried components was addressed at PVNGS during an inspection program in September 2002. Observations of this inspection program include: During the past several years, leaks developed in various buried piping segments, which potentially threaten the continuous operation of PVNGS. These leaks collectively indicated a negative trend in the overall integrity of the buried pipe.Palo Verde Nuclear Generating Station Amendment 20 Page B-61 License Renewal Application Appendix B AGING MANAGEMENT PROGRAMS Inspection and maintenance activities were implemented in order to address overall integrity of the buried pipe. Determination of system priorities and development of a draft inspection plan for each of the evaluated systems was developed.

The applicable systems with piping installed below grade were evaluated and assigned ranking based on priority; The majority of these evaluated buried piping systems have very little or no identified potential for degradation.

The majority of the systems evaluated in the inspection program are not within the scope of license renewal. The PVNGS corrective action documentation to date has shown that, for the systems within the scope of license renewal, degradation has been found primarily in the fire protection system. Fire protection system has had localized degradation in excess of the minimum wall requirement of 40% nominal wall thickness.

The designated segments of the degraded ductile iron piping have been replaced by fiberglass reinforced plastic piping. The fire protection system has not experienced a failure that affected the ability of the plant to achieve and maintain safe shutdown in the event of a fire. To date, the actual pipe failures of the underground fire protection system have been isolated and repaired without adversely affecting any fire protection water suppression system.Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.Conclusion The implementation of the Buried Piping and Tanks Inspection program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Palo Verde Nuclear Generating Station License Renewal Application Amendment 20 Page B-61A